Character and Source of Income from Internet Business Activities

By: Larissa B. Neumann, James P. Fuller

With the increasing interconnectedness of the global economy, the rapid advance of technology, and the ease with which information and services can move around the world, a clear understanding of the U.S. tax rules is vital to the long term success of any global technology-centered company. One of the most important issues in the taxation of U.S.-based multinational companies, particularly those companies that operate primarily in the internet business space, is the character and source of income.

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