Tax News

CCH (cch.taxgroup.com) reports:

Newly proposed regulations would provide guidance on the determination of the source of compensation for labor or personal services, particularly in regard to artists and athletes, through the application of a new "events basis" rule. Under the "events basis" rule, the source of the compensation, whether within or without the U.S., can usually be determined by considering, under the facts and circumstances of the case, the location of the event for which the person is compensated. Thus, under the proposal, the source of the compensation is the location where the event is held. Additional guidance is provided regarding whether or not the individual is compensated as an employee and for circumstances involving services performed in multiple locations.
The IRS has requested comments and requests for a public hearing on the proposed regulations. Written and electronic comments and requests for a hearing must be received by January 15, 2008.
Proposed Regulations, NPRM REG-114125-07, 2007FED ¶49,769
Other References:
Code Sec. 861
CCH Reference - 2007FED ¶27,129.105
CCH Reference - 2007FED ¶27,129.14
Tax Research Consultant
CCH Reference - TRC INTL: 3,200
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