Executive summary

United States (US) final regulations (T.D. 9921) on sourcing income from sales of personal property, including inventory (the Final Regulations), generally retain the basic approach of proposed regulations that were released in December 2019 to address changes made to Internal Revenue Code¹ Section 863(b)(2) by the Tax Cuts and Jobs Act (2017) (REG-100956-19) (the Proposed Regulat…