Michael Karlin co-authored an article for the Journal of International Taxation entitled, “On-Line, Off Base: The Computer Program Final Regulations Miss an Opportunity.” The article examines regulations published by the IRS and Treasury in September 1998 regarding the classification, for certain federal income tax purposes, of cross-border transactions involving computer programs and the lack of clarying guidance contained therein – particularly for U.S. software exporters competing in foreign markets.
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