Since the U.S. government issued software regulations almost 25 years ago, the provision of computing services has dramatically changed. Over the past few years, end-users have come to rely more and more on cloud computing for their computing needs. Cloud computing transactions typically are described for nontax purposes under one of three models: software as a service (SaaS), platform as a service (PaaS), and infrastructure as a service (IaaS). Unfortunately, the software regulations do not provide a comprehensive basis for categorizing cloud computing transactions.

In an article published by Tax Notes, A&M’s Lew Greenwald and Gianluca Mazzoni review the more recently proposed U.S. cloud regulations and compare the entity-by-entity approach with the lookthrough or unified approach.

Read Lew and Gianluca’s article here.