Name
International Taxation: Building on Sand: Character, Source, and the Taxation of AI-Generated Income
Speakers
Michael Plowgian, KPMG LLP
Lothar Determann, Baker & McKenzie LLP
Jason Yen, OpenAI
Shannon McCormack, Amazon
Lothar Determann, Baker & McKenzie LLP
Jason Yen, OpenAI
Shannon McCormack, Amazon
Date & Time
Thursday, January 14, 2027, 10:30 AM - 11:45 AM
Description
Copyright principles are the foundation in U.S. tax law for determining character (and source) of income derived from transactions in digital goods and services. The foundation is under stress, as the economy is increasingly dependent on AI-generated output, and the application of copyright law in this context is unstable, and still being developed. This panel will consider how to strike the balance, during this period of uncertainty, between using the existing copyright-based framework and the practical reality that it often does not provide a clear answer (if it applies at all).