Crediting (or Not) Foreign Countries’ Digital Services Taxes Under Section 903

4 Pages Posted: 7 Feb 2021 Last revised: 23 Jun 2021

Date Written: November 30, 2020

Abstract

This article considers whether digital services taxes are taxes “in lieu of a tax on income.” This has been one of the unanswered questions from the 2017 tax legislation that falls at the intersection of statutory and regulatory interpretation. In addition to the potential impact on the doctrine of Chevron deference, the resolution of this issue has ramifications for the future of the digital economy. Several articles have touched on this specifically and peripherally.

Keywords: digital services tax, tax law, international tax law, foreign tax credits

Suggested Citation

Lincoln IV, Charles Edward Andrew, Crediting (or Not) Foreign Countries’ Digital Services Taxes Under Section 903 (November 30, 2020). ABA Tax Times 2020, University of Groningen Faculty of Law Research Paper No. 56/2020, Available at SSRN: https://ssrn.com/abstract=3740147

Charles Edward Andrew Lincoln IV (Contact Author)

University of Groningen, Faculty of Law ( email )

Groningen
Netherlands

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