This session will delve into the intricacies of the U.S. taxation process for cross-border digital transactions, exploring key regulations such as "Software Regulations" and "Cloud Computing Regulations." Participants will gain insights into the tax implications of income derived from delivering digital services or products including withholding tax and foreign tax credit implications.  This session will emphasize an analytical approach to pinpoint relevant facts and pose critical questions. With a focus on clarifying the tax characterization of digital transaction income, participants will become adept at identifying scenarios where such income is classified as royalty income, services income, or sales of personal property. Join us as we navigate the complex world of cross-border digital taxation together.

Learning Objectives:

• Identify when income from a digital transaction is treated as royalty income


• Recognize scenarios where income from a digital transaction is classified as services income


• Determine situations where income from a digital transaction is considered a sale of personal property


• Define the critical sourcing rules that dictate the taxation of cross-border digital transactions