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Scenario: The City of Lazo enacts Ordinance No. LZ-2029-22 imposing Local Occupancy Tax (LOT) of 2.5% on gross receipts derived from lodging services conducted within the city, including receipts collected through online platforms that arrange stays in the city. The tax base is receipts earned from activities within the city only. A multinational online travel platform with no physical presence in Lazo challenges the ordinance, arguing that it taxes income beyond the city's territorial reach and that digital platforms cannot be taxed by the city. (a) Identify the controlling doctrine on the power of Local Government Units to tax businesses within their locality. (b) Distinguish the proper basis for a local occupancy tax and the territorial limits of the tax. (c) Apply the doctrine to the facts: Is Ordinance No. LOT-2029-22 valid as to its tax base and territorial scope? Explain.

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Clara

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