Date of Award


Degree Type


Degree Name

Doctor of Juridical Science (S.J.D.)

First Advisor

Prof. Reuven S. Avi-Yonah

Second Advisor

Prof. Phillip J. Adams

Third Advisor

Prof. Yoram Margalioth


The purpose of this dissertation is to examine the application of the U.S. and international tax rules and norms to income derived from online advertising, to consider the challenges and problems that arise when these rules are applied to such a purely-digital type of income, to propose an alternative framework for the taxation of online advertising, and to discuss the legislative measures adopted by various countries in an attempt to tax this type of income (and other income derived from digital-based activities).