Lawrence Lokken (Florida), Income Source in a Digital Age:

The source of income rules of the U.S. income tax laws require that income be sorted into a limited group of categories, including interest, dividends, rents, royalties, and gains on dispositions of property. The application of this sorting process to transactions in intellectual property has long been troublesome. The economic stakes of these troublesome issues have grown exponentially as the world of intellectual property has increasingly become digital. The U.S. Treasury adopted regulations in early 2025 addressing these issues.

This paper is a draft of material to be included in the treatise, Boris I. Bittker & Lawrence Lokken, Federal Taxation of Income, Estates & Gifts discussing the 2025 regulations.

Editor's Note:  If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.