Final Cloud Regulations: Classification of Digital and Cloud Transactions, Implementation, Proposed Sourcing Regs
A live 110-minute CPE webinar with interactive Q&A
This webinar will analyze the recently released final regulations, Classification of Digital Content Transactions and Cloud Transactions, as well as the proposed regulations for determining the source of income from cloud arrangements. Our panel of astute international tax attorneys will explain the key components of the recent final regulations and offer guidance to facilitate the implementation of the new requirements.
Outline
- Cloud regulations: introduction
- Definitions
- Final regulations
- Proposed regulations
- IRS Notice 2025-6
- Implementation
- Examples
Benefits
The panel will cover these and other critical issues:
- Determining the predominant character of digital transactions
- Key modifications made to the prior proposed regulations under the final regulations
- Rules contained in the newly proposed regulations for sourcing income
- Guidelines for implementing the key requirements of the final cloud regulations
Faculty
Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
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Pamela A. Fuller, Esq., J.D., LL.M.
Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Group
Ms. Fuller is a corporate and international tax attorney with over 20 years experience in advising a wide range of... | Read More
Ms. Fuller is a corporate and international tax attorney with over 20 years experience in advising a wide range of clients -- including private clients and companies, joint ventures, private equity funds, HNW indviduals, C-Suite executives, "start-ups," and government entities -- on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. She has deep expertise in structuring cross-border M&A transactions, and advising mobile international families. Her clients hail from a multitude of industries, including the burgeoning world of decentralized finance (DeFi). Pamela is also a seasoned taxpayer advocate, with decades of experience resolving complex U.S. federal, state, and foreign tax controversies.
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