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Notice 2020-78, page 1785.

Internal Revenue Bulletin 2020-53 · 2026-10-03 edition · updated 2026-10-04 · United States

The notice provides transition relief related to the work opportunity credit by giving employers additional time to submit a certification request to a Designated Local Agency for the targeted groups described in section 51(d)(5) and (7) of the Internal Revenue Code.

T.D. 9921, page 1767. These final regulations provide guidance on the sourcing of income from certain sales of personal property, including inventory, under section 863 of the Internal Revenue Code (“Code”), which was amended by the Tax Cuts and Jobs Act, Pub. L. No. 155-97 (2017) and also under section 865 of the Code. The final regulations also modify certain rules for determining whether foreign source income is effectively connected with the conduct of a trade or business within the United States under section 864 of the Code. The final regulations replace

previously issued proposed regulations and provide guidance on determining the source of income from sales of inventory produced within the United States and sold without the United States or vice versa and new rules for determining the source of income from sales of personal property by nonresidents that are attributable to an office or other fixed place of business that the nonresident maintains in the United States. Finally, the final regulations provide rules, pursuant to section 1502 of the Code, for the determination of source of income from sales of personal property in a consolidated group.

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▸Contents — Internal Revenue Bulletin 2020-53

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