Proposed rules that would modify the rules for determining the source of income from sales of inventory produced within the United States and sold without the United States or vice versa, issued by the IRS December 23. The proposed regulations also contain new rules for determining the source of income from sales of personal property (including inventory) by nonresidents that are attributable to an office or other fixed place of business that the nonresident maintains in the United States. Finally, these proposed regulations modify certain rules for determining whether foreign source income is effectively connected with the conduct of a…





















