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service provider does not show on an invoice where
such services are provided—
‘‘(A) the business entity shall treat the
services as if provided in the location to which
payment is sent, and
‘‘(B) the service provider shall treat as tax-
able receipts any payments received in the
United States.
‘‘(e) SPECIAL RULES PREVAIL.—See sections 268
and 269 for special rule relating to transportation and
communication services.
‘‘SEC. 268. INTERNATIONAL TRANSPORTATION SERVICES.
‘‘(a) TRANSPORTATION OF PROPERTY.—
‘‘(1) TAXABLE RECEIPTS.—
‘‘(A) EXPORTS.—Taxable receipts do not
include receipts from the transportation of
property exported from the United States.
‘‘(B) IMPORTS.—Taxable receipts include
receipts from transportation of property im-
ported into the United States only if such costs
are not taken into account in determining the
import tax.
‘‘(C) PRESUMPTIONS.—The Secretary shall
prescribe regulations describing situations in
which a transporter of property must presume
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that no import tax has been paid on the cost
of its services.
‘‘(2) BUSINESS PURCHASES.—
‘‘(A) EXPORTS.—Business purchases do
not include amounts paid or incurred for the
cost of transportation of property exported from
the United States.
‘‘(B) IMPORTS.—Amounts paid or incurred
for transportation of goods imported into the
United States, shall constitute a cost of busi-
ness purchase only to the extent that they are
taken into account in determining the customs
value for purposes of section 286(a) (relating
to the import tax).
‘‘(b) TRANSPORTATION OF PASSENGERS.—
‘‘(1) TAXABLE RECEIPTS.—Taxable receipts—
‘‘(A) include receipts from the transpor-
tation of passengers from the United States to
a destination outside the United States, but
‘‘(B) do not include receipts from the
transportation of passengers from outside the
United States to a destination in the United
States.
‘‘(2) 
BUSINESS
PURCHASES.—Business
purchases—
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‘‘(A) include amounts paid or incurred in
a business activity for the transportation of
passengers from the United States to a destina-
tion outside the United States, but
‘‘(B) do not include amounts paid or in-
curred for transportation of passengers from
outside the United States to a destination in
the United States.
‘‘(3) SIMPLIFYING RULES.—The Secretary may
provide rules that simplify this subsection, including
rules under which—
‘‘(A) half of receipts attributable to trans-
portation to or from the United States are
treated as taxable receipts,
‘‘(B) half of the cost for business trips to
and from the United States are treated as busi-
ness purchases, and
‘‘(C) all transportation expenses of a busi-
ness entity that has no regular business outside
the United States are treated as business pur-
chases.
‘‘SEC. 269. INTERNATIONAL COMMUNICATIONS.
‘‘(a) IN GENERAL.—For purposes of section 266,
communications services shall be treated as provided at
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the point of origin of the communications and shall not
be treated as imported or exported.
‘‘(b) COMMUNICATIONS SERVICES.—Communications
services include—
‘‘(1) telephone communications services,
‘‘(2) courier services (except in the case of
transportation of property that is imported or ex-
ported),
‘‘(3) satellite transmission services,
‘‘(4) telegraph services,
‘‘(5) facsimile transmission services, and
‘‘(6) other similar services.
‘‘SEC. 270. INSURANCE.
‘‘(a) IN GENERAL.—Insurance services will be treat-
ed as provided at the location of the insurance company
providing the services. Except as the Secretary may pre-
scribe by regulations, insurance companies will be treated
as providing services at the location to which insurance
payments are made.
‘‘(b) INSURED RISKS IN THE UNITED STATES.—If
insurance services are provided outside the United States
and the insured risk is located in the United States—
‘‘(1) the insurance service shall be treated as
imported,