Comments Requested on Services FTC Licensing Exception
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Comments Requested on Services FTC Licensing Exception
Speaking on June 7 at a Texas Federal Tax Institute conference, Tracy Villecco of the IRS Office of Associate Chief Counsel (International) said the government is open to hearing comments on a fact pattern “where the withholding payment on a service payment is in respect to services performed within that source jurisdiction, similar to the single-country exception for royalties.”
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