Date: 2019-08-14
Links to Federal Register: HTML, PDF
Document Number: 2019-17425, RIN: 1545-BM41
Action: Notice of proposed rulemaking.
Abstract: This document contains proposed regulations regarding the classification of cloud transactions for purposes of the international provisions of the Internal Revenue Code. These proposed regulations also modify the rules for classifying transactions involving computer programs, including by applying the rules to transfers of digital content.
| Notable phrases | Frequency |
|---|---|
| digital content | 112 |
| on-demand network access | 21 |
| lease of property | 13 |
| computer program digital content | 11 |
| classified as (a|the) provision of services | 11 |
| software development platform | 10 |
| transactions involving digital content | 9 |
| non-de minimis right | 9 |
| transfer of a copyright right | 9 |
| protected by copyright law | 8 |
| significant economic or possessory interest | 7 |
| on-demand network access to computer hardware | 6 |
| installation onto the end-user's device | 6 |
| neither physical possession of nor control | 5 |
| location of download or installation | 5 |
| risk of substantially diminished receipts | 5 |
| Reg. Cites | Frequency |
|---|---|
| 1.861-18 | 54 |
| 1.861-19 | 16 |
| 1.861-18(a)(3) | 10 |
| 1.861-7(c) | 8 |
| 1.861-18(f)(2)(ii) | 6 |
| 1.446-1(e) | 3 |
| 1.861-19(c)(2) | 2 |
| 1.861-7 | 2 |
| 1.937-3 | 2 |
| Sec. Cites | Frequency |
|---|---|
| 7701(e)(1) | 6 |
| 59A | 4 |
| 446(e) | 4 |
| 861 | 3 |
| 842 | 2 |
| 679 | 2 |
| 861(a)(6) | 2 |
| 861(a)(4) | 2 |
Statistics
Number of pages: 13, words: 14,538, sentences: 508
Average words per sentence: 28