Comments requested under Notice 2025-6 on extending rules to all provisions of the Code
The U.S. Treasury Department and IRS (collectively, Treasury) today released final regulations relating to the classification of digital content and cloud transactions for purposes of the international provisions of the Code. Treasury also released proposed regulations related to the source of income from cloud transactions.
Treasury today also issued Notice 2025-6 requesting comments on any potential implications if the characterization rules contained in Treas. Reg. §§ 1.861-18 and 1.861-19, as amended and added, respectively, by the final regulations, were to apply to all provisions of the Code, including the need for additional guidance, and seeks specific comments on the possible impacts and guidance that may be necessary with respect to certain identified provisions.