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Treas. Reg. 1.861-18(a)-(b): what a digital content transaction is and its four categories, United States (federal)

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

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Last checked 18 Oct 2026

What was read from it

Records read from this source
Record	Kind	As stated	Dated
Treas. Reg. 1.861-18(a)-(b): what a digital content transaction is and its four categories (26 CFR 1.861-18(a)(2), (b)(1))	Law or ruling	The IRS sorts a transfer of digital content (text, code, audio, video) into one of four…	18 Oct 2026
Treas. Reg. 1.861-18(c): copyright rights and copyrighted articles (26 CFR 1.861-18(c)(2), (c)(3))	Law or ruling	A licence that lets the buyer only keep and use a copy for its own training looks like a…	18 Oct 2026
Treas. Reg. 1.861-18(d)-(e): services to develop digital content, and know-how (26 CFR 1.861-18(d), (e))	Law or ruling	Work to create new content for a buyer is a service when the facts show the buyer is to…	18 Oct 2026
Treas. Reg. 1.861-18(f)(1): a transfer of a copyright right is a sale or a licence, and a licence is sourced as a royalty (26 CFR 1.861-18(f)(1))	Law or ruling	If a holder keeps substantial rights in its content and lets the buyer use it, the IRS…	18 Oct 2026
Treas. Reg. 1.861-18(f)(2)-(3): a copy that is not truly sold is a lease, and a delete-after-a-period rule is a lease (26 CFR 1.861-18(f)(2), (f)(3))	Law or ruling	A term-limited licence where the buyer must delete the data after a period is treated…	18 Oct 2026
Treas. Reg. 1.861-18(f)(2)(ii): sourcing of a sold copy, and the billing-address rule for electronic delivery (26 CFR 1.861-18(f)(2)(ii))	Law or ruling	If a data deal is a sale of a copy, it is not a royalty and follows the sale-sourcing…	18 Oct 2026
Treas. Reg. 1.861-18(g)(1) and (i): the label on the contract does not decide, and the rule's start date (26 CFR 1.861-18(g)(1), (i)(1))	Law or ruling	Calling a deal a licence does not make it a royalty for tax. The IRS looks at what the…	18 Oct 2026

Treas. Reg. 1.861-18(a)-(b): what a digital content transaction is and its four categories (26 CFR 1.861-18(a)(2), (b)(1))
Kind
Law or ruling
As stated
The IRS sorts a transfer of digital content (text, code, audio, video) into one of four…
Dated
18 Oct 2026
Treas. Reg. 1.861-18(c): copyright rights and copyrighted articles (26 CFR 1.861-18(c)(2), (c)(3))
Kind
Law or ruling
As stated
A licence that lets the buyer only keep and use a copy for its own training looks like a…
Dated
18 Oct 2026
Treas. Reg. 1.861-18(d)-(e): services to develop digital content, and know-how (26 CFR 1.861-18(d), (e))
Kind
Law or ruling
As stated
Work to create new content for a buyer is a service when the facts show the buyer is to…
Dated
18 Oct 2026
Treas. Reg. 1.861-18(f)(1): a transfer of a copyright right is a sale or a licence, and a licence is sourced as a royalty (26 CFR 1.861-18(f)(1))
Kind
Law or ruling
As stated
If a holder keeps substantial rights in its content and lets the buyer use it, the IRS…
Dated
18 Oct 2026
Treas. Reg. 1.861-18(f)(2)-(3): a copy that is not truly sold is a lease, and a delete-after-a-period rule is a lease (26 CFR 1.861-18(f)(2), (f)(3))
Kind
Law or ruling
As stated
A term-limited licence where the buyer must delete the data after a period is treated…
Dated
18 Oct 2026
Treas. Reg. 1.861-18(f)(2)(ii): sourcing of a sold copy, and the billing-address rule for electronic delivery (26 CFR 1.861-18(f)(2)(ii))
Kind
Law or ruling
As stated
If a data deal is a sale of a copy, it is not a royalty and follows the sale-sourcing…
Dated
18 Oct 2026
Treas. Reg. 1.861-18(g)(1) and (i): the label on the contract does not decide, and the rule's start date (26 CFR 1.861-18(g)(1), (i)(1))
Kind
Law or ruling
As stated
Calling a deal a licence does not make it a royalty for tax. The IRS looks at what the…
Dated
18 Oct 2026