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

Charlie Lincoln IV

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

Protecting European Citizens and Market Participants

Research output: Contribution to journal › Article › Academic › peer-review

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.

Source: https://www.americanbar.org/groups/taxation/publications/abataxtimes_home/20fal/20fal-pp-lincoln-dst-under-sec-903/

Author: Charles Edward Andrew Lincoln IV

Original language	English
Pages (from-to)	5-8
Number of pages	4
Journal	ABA Tax Times
Volume	40
Issue number	1
Publication status	Published - 30-Nov-2020

Keywords

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

Access to Document

https://www.americanbar.org/groups/taxation/publications/abataxtimes_home/20fal/20fal-pp-lincoln-dst-under-sec-903/

Handle.net

Persistent link

Cite this

@article{711b78a47ce349dbb7fb65f06ffb0459,

title = "Crediting (or Not) Foreign Countries{\textquoteright} Digital Services Taxes Under Section 903",

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.Source: https://www.americanbar.org/groups/taxation/publications/abataxtimes_home/20fal/20fal-pp-lincoln-dst-under-sec-903/Author: Charles Edward Andrew Lincoln IV",

keywords = "tax, international tax, foreign tax credits, digital services, dst tax, international, taxation",

author = "{Lincoln IV}, Charlie",

note = "Charles “Charlie” Lincoln graduated with an LL.M. in Tax Law from Boston University in May 2018. Charlie graduated with an Advanced LL.M. in International Tax Law from the University of Amsterdam in October 2017. He graduated from Texas A&M University School of Law with a J.D. in May 2016. He graudated cum laude from Harvard University with a bachelor's degree in May 2013. Currently, he is a Ph.D. student focusing on international tax law at the University of Groningen (abbreviated as UG Dutch: Rijksuniversiteit Groningen, abbreviated as RUG). ",

year = "2020",

month = nov,

day = "30",

language = "English",

volume = "40",

pages = "5--8",

journal = "ABA Tax Times",

publisher = "Americn Bar Association",

number = "1",

}

TY - JOUR

T1 - Crediting (or Not) Foreign Countries’ Digital Services Taxes Under Section 903

AU - Lincoln IV, Charlie

N1 - Charles “Charlie” Lincoln graduated with an LL.M. in Tax Law from Boston University in May 2018. Charlie graduated with an Advanced LL.M. in International Tax Law from the University of Amsterdam in October 2017. He graduated from Texas A&M University School of Law with a J.D. in May 2016. He graudated cum laude from Harvard University with a bachelor's degree in May 2013. Currently, he is a Ph.D. student focusing on international tax law at the University of Groningen (abbreviated as UG Dutch: Rijksuniversiteit Groningen, abbreviated as RUG).

PY - 2020/11/30

Y1 - 2020/11/30

N2 - 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.Source: https://www.americanbar.org/groups/taxation/publications/abataxtimes_home/20fal/20fal-pp-lincoln-dst-under-sec-903/Author: Charles Edward Andrew Lincoln IV

AB - 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.Source: https://www.americanbar.org/groups/taxation/publications/abataxtimes_home/20fal/20fal-pp-lincoln-dst-under-sec-903/Author: Charles Edward Andrew Lincoln IV

KW - tax

KW - international tax

KW - foreign tax credits

KW - digital services

KW - dst tax

KW - international

KW - taxation

M3 - Article

VL - 40

SP - 5

EP - 8

JO - ABA Tax Times

JF - ABA Tax Times

IS - 1

ER -