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

Research output: Contribution to journalArticleAcademicpeer-review


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.


Author: Charles Edward Andrew Lincoln IV
Original languageEnglish
Pages (from-to)5-8
Number of pages4
JournalABA Tax Times
Issue number1
Publication statusPublished - 30-Nov-2020


  • tax
  • international tax
  • foreign tax credits
  • digital services
  • dst tax
  • international
  • taxation

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