2505005 Informal Interpretation

I know you have been receiving questions about how the instructions on reporting US NAICS revenue differs under the new rules compared to the old rules. For example, I understand that we are no longer required to report revenue from products manufactured overseas and sold directly to US customers (i.e., not through an owned US distributor). I had just two clarification questions on this:

• Previous guidance, for example interpretation 1405003, suggested that revenues should have been reported in Item 5 under the old Form if they were booked by a US entity, even if they related to a service provided outside the US. Does this guidance still hold true under the new rules? Should we report all revenue booked by US entities (organized under US law or with their principal offices in the US), regardless of whether the revenue relates for example to services provided outside the US or products manufactured overseas and sold directly to US customers?
• Much of the guidance around this issue references either services, manufactured products, or wholesaled products. For oil and gas extraction activities, such as those that would be reported under code 211120, should we think about those in the same way as manufactured products? So for example, if a company extracts petroleum from the ground outside the United States, ships it from a non-owned pipeline beginning outside the United States and ending up with a customer inside the United States, would that revenue not be reported on the Form so long as it was not booked by a US entity?