Touro Law Review
This article is divided in the following parts. Part II will discuss and define what Section 903 stands for from a legislative, regulatory, and case perspective. Part III will discuss what digital services taxes are. Part III will define “nexus” and how the concept of “nexus” will relate to Section 903. Part IV concludes by suggesting that digital services taxes do not fall into the traditional statutory paradigm. Ultimately, Section 903 hypothecates that a tax will either be a traditional income tax creditable under Section 901 or tax in the place of that tax. If it does not fall into this category, then it is a tax in addition.
Touro College School of Law
Charles E. Lincoln IV,
Are Digital Services Taxes Imposed by Other Countries Creditable Under IRC Section 903? Yes. But, What if the Opposite Is True?,
Touro L. Rev.
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