Records / Laws and rulings

Treas. Reg. 1.861-18(f)(1): a transfer of a copyright right is a sale or a licence, and a licence is sourced as a royalty (26 CFR 1.861-18(f)(1))

If a holder keeps substantial rights in its content and lets the buyer use it, the IRS treats the deal as a licence and the fee as a royalty sourced by where the content is used.

Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text

Figures it counts in

It is shown on its own, not counted into a figure.

Treas. Reg. 1.861-18(f)(1): a transfer of a copyright right is a sale or a licence, and… | AIData.Broker