About the Course
Introduction
This CLE/CPE course will provide tax counsel and advisers a detailed analysis of the taxation of digital content, products, software as a service (SaaS), and cloud transactions. The panel will discuss applicable IRS tax rules and regulations, sourcing of income rules and challenges, treatment of payment of services versus lease payments, treatment of fees for the right to use digital content, issues presented by the base erosion anti-abuse tax (BEAT), net CFC tested income (NCTI), formerly GILTI, Foreign-Derived Deduction Eligible Income (FDDEI), formerly FDII rules, and other vital items impacting taxpayers engaging in digital content, products, and SaaS.
Description
IRS regulations address the classification of digital content and cloud transactions under the source of income rules of the Internal Revenue Code. Tax professionals must understand critical issues regarding the tax treatment of digital content, SaaS, and cloud transactions to properly advise and implement planning techniques to minimize tax liability to taxpayers.
The IRS generally treats cloud transactions as payments for services as opposed to a lease of property. However, some transactions, such as digital downloads or content transfers, could be classified as a lease of property under some circumstances. Tax professionals must also grasp crucial factors in determining classification as services versus leases and the tax treatment of each category.
The regulations have significant implications on cross-border transactions, providing the source of income from digital transactions as being the place where the download of the digital content occurred, potentially subjecting taxpayers to multijurisdictional tax obligations. Furthermore, taxpayers must also consider the impact of other federal tax provisions, such as the BEAT regime, the U.S. tax treatment under the CFC regime, and the FDDEI, formerly the FDII regime.
Listen as our panel discusses key provisions and challenges of the recent regulations on cloud transactions and digital content, IRS treatment of payment of services versus lease payments, unresolved issues stemming from BEAT, NCTI, and FDDEI rules, and other essential items impacting taxpayers engaging in cloud transactions and digital content.
Presented By
Mr. Dimon concentrates his practice on a wide variety of domestic and international tax matters, including both tax planning and tax controversy. He has worked with clients from equally varied backgrounds, including cutting-edge startups and large Fortune 100 companies.
Mr. Nagaraj is a Senior Manager with expertise in International Tax scenario planning, compliance and cross border tax issues with an understanding of Transfer Pricing, audit and tax accounting considerations. He has an in- depth experience in Inbound and outbound issues, IP planning, Pillar 2 taxation, withholding tax and scenario modeling. Mr. Nagaraj has an Advanced Diploma in International Taxation focused in US International taxation and Transfer Pricing from The Chartered institute of taxation, UK and also a CPA from the AICPA, USA.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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CPE credit is not available on recordings.
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BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Date + Time
- event
Thursday, July 23, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Recent IRS regulations and applicable tax rules
II. Sourcing of income rules and challenges
III. IRS treatment of payment of services, lease payments, and rights to use digital content
IV. Tax implications of BEAT, NCTI, and FDDEI rules in relation to cloud transactions and digital content
V. Best practices for tax counsel and advisers to ensure tax compliance for cloud transactions and digital content
The panel will review these and other key issues:
- Impact of OBBBA and recent IRS regulations covering the tax treatment of cloud transactions and transfers of digital content
- Lease vs. services treatment in cloud transactions
- Digital content transfers and the tax treatment of payments for the purchase of or the right to use software or other digital content
- Sourcing rules and pitfalls to avoid unnecessary tax liability
- Additional federal income tax implications: BEAT, NCTI, FDDEI
Learning Objectives
After completing this course, you will be able to:
- Recognize the impact of recent IRS regulations on the tax treatment of cloud transactions and transfers of digital content
- Understand IRS lease vs. services treatment in cloud transactions
- Identify critical issues in the tax treatment of payments for the purchase of or the right to use software or other digital content
- Recognize factors in the application of sourcing rules and pitfalls to avoid unnecessary tax liability
- Identify the tax implications of BEAT, NCTI, and FDDEI rules concerning cloud transactions and digital content
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or professional experience at mid-level within the organization, preparing complex tax forms and schedules. Specific knowledge and understanding of corporate and partnerships taxation, international taxation, deferred foreign-source income, earnings and profits, sales and use taxation; tax implications in the purchase and sale of assets.
BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
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