Source of Income From Cloud Transactions; Hearing

Internal Revenue Service (IRS), Treasury.

Notice of proposed rulemaking; notice of hearing.

This document provides a notice of public hearing on proposed rules for determining the source of income from cloud transactions for purposes of the international provisions of the Internal Revenue Code.

The public hearing on these proposed rules has been scheduled for Thursday, July 17, 2025, at 10:00 a.m. Eastern Time (ET). The IRS must receive speakers' outlines of the topics to be discussed at the public hearing by June 17, 2025. If no outlines are received by June 17, 2025, the public hearing will be cancelled.

The public hearing is being held in the Auditorium, at the Internal Revenue Service Building, 1111 Constitution Avenue NW, Washington, DC. Due to security procedures, visitors must enter at the Constitution Avenue entrance. In addition, all visitors must present a valid photo identification to enter the building. Because of access restrictions, visitors will not be admitted beyond the immediate entrance area more than 30 minutes before the hearing starts. Participants may alternatively attend the public hearing by telephone.

Send submissions to CC:PA:01:PR (REG-107420-24), Room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand delivered Monday through Friday to CC:PA:01:PR (REG-107420-24), Couriers Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC 20224 or sent electronically via the Federal eRulemaking Portal at www.regulations.gov (REG-107420-24).