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

Charlie Lincoln IV

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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

Originele taal-2	English
Pagina's (van-tot)	5-8
Aantal pagina's	4
Tijdschrift	ABA Tax Times
Volume	40
Nummer van het tijdschrift	1
Status	Published - 30-nov.-2020

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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",

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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). ",

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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

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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

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KW - international tax

KW - foreign tax credits

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

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