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Treas. Reg. 1.1441-2(b): what counts as fixed or determinable income, lump sums included, and why sale gains do not, United States (federal)

2 records were read from this source, dated 18 Oct 2026.

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Last checked 18 Oct 2026

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Records read from this source
Record	Kind	As stated	Dated
Treas. Reg. 1.1441-2(b): what counts as fixed or determinable income, lump sums included, and why sale gains do not (26 CFR 1.1441-2(b)(1)(i)-(ii), (b)(2)(i))	Law or ruling	A one-time lump-sum licence fee is still withholdable income, and so is a fee paid in…	18 Oct 2026
Treas. Reg. 1.1441-2(a): if the source of a payment cannot be determined, it is treated as US-source (26 CFR 1.1441-2(a))	Law or ruling	A buyer that cannot show where the data will be used must treat the royalty as US-source…	18 Oct 2026