This document contains regulations relating to the tax treatment of certain transactions involving the transfer of computer programs. The regulations provide rules for classifying such transactions as sales or licenses of copyright rights, sales or leases of copyrighted articles, or the provision of services, or of know-how, under certain provisions of the Internal Revenue Code and tax treaties. These regulations are necessary to give taxpayers guidance on the taxation of computer program transactions. These regulations affect taxpayers engaging in certain transactions involving computer programs.