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In 2023, we summarized the U.S. Department of Treasury report that raised concerns about the growing reliance of financial institutions (FIs) on cloud computing. Treasury highlighted structural imbalances and regulatory blind...more
The U.S. Department of Treasury (Treasury) released final and proposed regulations under § 861 of the Code addressing the U.S. federal income tax classification of digital content and cloud computing transactions (the “Final...more
On Aug. 14, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published proposed regulations (the Proposed Regulations) regarding the classification of “cloud transactions” for...more