Crediting (or Not) Foreign Countries’ Digital Services Taxes Under Section 903
ABA Tax Times 2020
4 Pages Posted: 7 Feb 2021
Date Written: November 30, 2020
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
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