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Question
X City enacts Ordinance No. 2025-04 imposing a 3% gross receipts tax on any entity that provides an online platform to residents of the City, regardless of whether the operator has any physical presence in the Philippines. Platform B is a foreign corporation with no office, employees, or property in the Philippines, but it offers streaming services to City residents through its digital platform. Platform B challenges the ordinance as an extraterritorial tax beyond local taxing power; the City defends it as a valid exercise of its power to tax commerce within its territory. Answer the following: (a) Identify the controlling constitutional doctrine governing the validity of such local taxation of a digital platform with no local presence. (b) Distinguish the controlling rule between local taxation of nonresident digital platforms and national taxation of Philippine-source income. (c) Apply the doctrine to the facts and determine whether the ordinance is constitutional. If not, explain the appropriate framework to tax digital services in the Philippines and the remedies for the City.