Date: 2020-12-11
Links to Federal Register: HTML, PDF
(Proposed Regulation: REG-100956-19 HTML, PDF)
Document Number: 2020-21817, RIN: 1545-BP16
Action: Final regulations.
Abstract: This document contains final regulations modifying the rules for determining the source of income from sales of inventory produced within the United States and sold without the United States or vice versa. These final regulations also contain new rules for determining the source of income from sales of personal property (including inventory) by nonresidents that are attributable to an office or other fixed place of business that the nonresident maintains in the United States. Finally, these final regulations modify certain rules for determining whether foreign source income is effectively connected with the conduct of a trade or business within the United States.
| Notable phrases | Frequency |
|---|---|
| (within|without) the United States | 77 |
| production activit(y|ies) | 73 |
| source of (gross) income | 30 |
| office or other fixed place of business | 29 |
| outside the United States | 23 |
| within the meaning of section 267 or 707 | 18 |
| gross income, gain, or loss | 17 |
| sale of personal property | 14 |
| persons related to the taxpayer | 13 |
| within and without the United States | 13 |
| adjusted basis of production assets | 11 |
| properly allocable to an office | 7 |
| effectively connected with the conduct of a trade or business in the United States | 5 |
| Reg. Cites | Frequency |
|---|---|
| 1.863-3 | 34 |
| 1.865-3 | 33 |
| 1.863-1 | 14 |
| 1.954-3(a)(4) | 12 |
| 1.865-3(d)(2)(ii)(B) | 11 |
| 1.863-8 | 10 |
| 1.864-6 | 7 |
| 1.864-5 | 7 |
| 1.863-3(c)(2) | 7 |
| 1.1502-13 | 6 |
| 1.863-2(b) | 6 |
| 1.863-8(b)(3)(ii) | 6 |
| 1.864-6(c)(2) | 6 |
| 1.863-1(b) | 6 |
| 1.864-5(a) | 6 |
| 1.863-2 | 5 |
| 1.861-7(c) | 5 |
| 1.954-3(a)(4)(iv) | 5 |
| 1.863-3(c)(1)(i) | 4 |
| Sec. Cites | Frequency |
|---|---|
| 865(e)(2) | 19 |
| 267 | 18 |
| 863(b) | 15 |
| 863(b)(2) | 14 |
| 863 | 9 |
| 865(g)(1)(B) | 7 |
| 863(a) | 6 |
| 168(k) | 5 |
| 168(g)(2) | 5 |
| 482 | 5 |
| 865(i)(1) | 3 |
| 861 | 3 |
| 1011 | 2 |
| 862(a)(6) | 2 |
| 904 | 2 |
| 865(b) | 2 |
| 882(c)(1) | 2 |
| 864(c)(5) | 2 |
| 7701(b)(1)(B) | 2 |
Statistics
Number of pages: 17, words: 17,657, sentences: 765
Average words per sentence: 23