Proposed revisions to the regulation addressing apportionment of margin include changes relating to the rules for sourcing service receipts. The proposed changes to the regulation include guidance on interpreting the location where a service is considered performed, and generally, a service will be performed at the location of the receipts-producing, end-product act or acts—a new test that aligns with language adopted by the appeals court in the Sirius XM case. There are also numerous other changes in the proposed regulation
Source: KPMG
