Computing Tax in the Cloud: State and International Implications 2011 (Audio-only)

Taken from the briefing Computing Tax in the Cloud: State and International Implications recorded December, 2011.

Taxpayers, practitioners, and tax administrations (state, Federal, and foreign) have struggled to keep up with recent advances in technology that in some cases change how goods and services are provided to individuals and businesses.  Just as the rules concerning taxation of e-commerce business have become more settled, a new challenge has emerged, in the form of transactions conducted entirely on shared platforms, a/k/a the “cloud.”  This poses difficult questions in terms of characterizing income for tax purposes, as well as sourcing and allocation between domestic and foreign tax jurisdictions.

This Briefing, featuring Carl R. Erdmann and John M. Breen of Skadden, Arps, Slate, Meagher & Flom LLP, will provide an overview of key Federal, international, and state and local tax aspects of cloud computing.

Lecture Topics  [Total Time: 01:04:36]

• New business models:  cloud computing defined
• Does a cloud computing transaction result in contacts with a specific jurisdiction: Overview of jurisdictional issues including nexus, trade or business, and Permanent Establishment issues
• Is cloud computing a product, service, or something else?
• A review of sourcing and apportionment issues
• Impact on state, local and Federal tax credits and other incentives

Presentation Material

• Computing Tax in the Cloud: State and International Implications
  John M. Breen, Carl R. Erdmann