Records / Laws and rulings

Treas. Reg. 1.861-18(f)(2)(ii): sourcing of a sold copy, and the billing-address rule for electronic delivery (26 CFR 1.861-18(f)(2)(ii))

If a data deal is a sale of a copy, it is not a royalty and follows the sale-sourcing rules, with a deemed place of sale at the buyer's billing address when the data is delivered electronically.

Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text

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