Abstract

The digital economy has reshaped how services are delivered, accessed, and experienced. Activities that were once performed and received in identifiable locations now unfold across cloud infrastructure, mobile networks, and remote work environments that span multiple jurisdictions simultaneously. As a result, longstanding assumptions underlying market-based sourcing regimes are under increasing strain. This article provides a descriptive examination of the operational architecture of digital services and explains why customer location has become an increasingly unstable indicator of where service benefits are realized.

The analysis does not offer legal interpretations or policy recommendations. Instead, it focuses on how digital services actually operate and why their distributed nature complicates multistate sourcing analysis. By shifting attention from taxpayer behavior to system design, the article clarifies the structural challenges inherent in applying geographic sourcing concepts to a stateless digital economy.

DOI: doi.org/10.63721/26JESD0134

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