This Article proceeds as follows: Part I reviews the traditional U.S. international tax policy, followed by Part II that highlights the impact of the Tax Cuts and Jobs Creation Act of 2017 on such policy. Part III provides context to the proposals made by this Article with a discussion of the international discourse over the challenges that the digital economy presents to the international tax regime, while Part IV exposes and explains the role of the United States in this discourse. Finally, the Article concludes with modest proposals for U.S. action in response to the challenges presented by digital economy to its tax rules, proposals that could finally also consider the true position of the United States in the global economy.
Yariv Brauner, Thinking Like a Source State in a Digital Economy, 18 Pitt. Tax Rev. 225 (2021)