N-2025-06: Request for Comments on Applying the Characterization Rules in §§1.861-18 and 1.861-19 to All Provisions of the Internal Revenue Code

Notice 2025-06 requests comments on any potential implications if the characterization rules currently contained in §§1.861-18 and 1.861-19, as amended and added, respectively, by Treasury Decision 10022, were to apply to all provisions of the Internal Revenue 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. The Department of the Treasury and the Internal Revenue Service have published Treasury Decision 10022 containing final regulations that provide rules for characterizing digital content and cloud transactions. Treasury Decision 10022 applies solely to certain enumerated international provisions of the Internal Revenue Code.

Notice 2025-06 will be in IRB: 2025-8, dated 2/18/2025.

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