Issue Brief by Senior Policy Analyst, Cody Allen | callen@csg.org

DOWNLOAD

---

In a world of smartphones, connected devices, and the continuing decline in traditional media consumption, consumers are never far from advertisements—particularly when utilizing social media. Targeted digital advertising has increased on these platforms, leading to tax assessments in most of the world. By 2019, digital advertising spending outpaced traditional media advertising—which included television, radio, and print ads—by more than $20 billion, and has increased year-over-year, reaching a nearly $68 billion difference by 2021.¹

More shockingly, digital advertising, whose market share was less than half of traditional media advertising’s share in 2015, now makes up more than 50 percent of total advertising spending and continues to grow apace from older advertising models. Per research from the Interactive Advertising Bureau and PricewaterhouseCoopers, digital advertising grew by 15 percent from 2023 to 2024, with the total spend exceeding $258 billion in 2024.²

FIGURE 1. Online Advertising Revenue in the U.S. from 2000 to 2024 (in billions of USD)

As social media platforms expand their ever-growing reach and overtake traditional advertising spaces, several states have proposed—and Maryland enacted—legislation to level the playing field and establish a surcharge or tax on provider services or paid advertisements to support anti-cyberbullying programs, investigation and prosecution of cybercrimes, and rural broadband initiatives.⁴

Other states—including five in the South (Arkansas, Louisiana, Tennessee, Texas, and West Virginia)—have proposed similar measures targeting digital advertising or social media advertising to various extents, but failed to make it out of committee or, in Louisiana’s case, passed committee but did not receive a third reading on the House floor.

FIGURE 2. Five-Year-Trend in Internet Advertising Revenue (in billions)

As states attempt to fund solutions to the pandemic-escalated mental health crisis and digital divide, these revenues may support funding essential services. Whether as a formal study committee or legislation, this issue will undoubtedly continue to be watched as states and providers anxiously await a resolution to legal challenges—not dissimilar to the June 2018 U.S. Supreme Court opinion in South Dakota v. Wayfair Inc., et al., which upended state sales tax nexus debates across the country.⁶

This CSG South publication examines the current state landscape surrounding digital and social media advertising and estimates potential impacts on Southern states.

The Bay State: A First from Maryland

Maryland is the first (and only) state to date to implement a social media advertising tax with the passage of House Bill 732 (2020) and a subsequent veto override. The veto message from the Governor raised concerns over the legality of taxing internet services and political issues surrounding expanding the existing tax base.⁷ However, on April 22, 2020, the state’s Attorney General found that the law was “not clearly unconstitutional” and that any future legal issues would not affect the severability of the act’s constituent parts.⁸

In an effort to address implementation concerns, lawmakers filed legislation the following year—Senate Bill 787 (2021)—to postpone the implementation of the new tax until January 2022, exempt broadcast and news media entities from the digital advertising services tax, and prohibit entities from directly passing on the tax to consumers via a separate and distinct fee, surcharge, or line-item.⁹

The law defines digital advertising services as advertisements on a digital interface, including banner advertising, search engine advertising, interstitial or pop-up advertising, and other comparable digital or internet-based advertising.¹⁰ Subsequent state efforts have maintained similar or identical definitions. The taxable base is generated by a formula that divides the taxpayer’s annual gross revenues (AGR) derived from digital advertising services in the state by those derived from services provided nationwide.¹¹

As constructed, the tax is tiered based on AGR as follows:

• 2.5 percent of the assessable base if global AGR is more than $100 million up to $1.0 billion;
• 5.0 percent of the assessable base if global AGR is more than $1 billion up to $5 billion;
• 7.5 percent of the assessable base if global AGR is more than $5 billion up to $15 billion; and
• 10.0 percent of the assessable base if global AGR exceeds $15 billion.¹²

Revenues from the tax are distributed to the “Blueprint for Maryland’s Future Fund” for educational purposes, after the Comptroller’s costs to administer the tax are deducted.¹³

The initial fiscal note estimated that the state could collect $250 million in tax revenue in its first full year of implementation. However, the note admitted that potential litigation and compliance issues would likely delay or impact potential revenues. Among compliance issues raised by legislative analysts are tracking users served by ads while utilizing a virtual private network or when crossing at or near state borders.¹⁴

However, per a February 3, 2025, statement from the Maryland Comptroller and reporting from the tax firm Shulman Rogers, revenues have been significantly lower than these estimates due to ongoing litigation and delayed implementation, with less than $100 million in revenues in fiscal years 2022 and 2023.¹⁵ Exact revenues have not been made public due to litigation, making a precise analysis difficult.

FIGURE 3. Estimated Digital Advertising Tax Revenues (2022-2023)

As anticipated, given the measure’s unprecedented nature, the state faced several legal challenges in state and federal court. The primary claim brought by challengers surrounds the 1998 federal Internet Tax Freedom Act (ITFA), which prohibited states from taxing online commerce if similar analog technologies are not taxed. Much of the legal debate surrounds the meaning of the term “similar” and what constitutes such technologies in the current landscape, as court determinations are the only source of guidance on ITFA definitions.¹⁷

The ITFA preempts taxes on internet access and multiple or discriminatory taxes on electronic forms of commerce. First enacted in 1998, the law became permanent and inclusive of all U.S. states on June 30, 2020.¹⁸

In March 2022, a federal judge dismissed the challenge’s first three counts, arguing that the law violated the ITFA and the Commerce and Due Process clauses of the U.S. Constitution. Later that same year, before the U.S. District Court for the District of Maryland, the state defeated a First Amendment challenge from companies that argued that the pass-through prohibition of the law prohibited the pass-through provisions from being directly applied to consumers. The opinion also stated that the statutes’ possibly “unconstitutional applications do not substantially outweigh its constitutional ones.”²⁰

FIGURE 4. Significant Milestones and Path to Permanency of the Federal Internet Tax Freedom Act

On July 12, 2023, the Maryland Supreme Court threw out a challenge to the tax, and the battlefield will now shift to state tax court cases filed by individual taxpayers and federal court cases.²¹ While no court has yet ruled the tax itself unconstitutional, its legal travails are far from finished, as opponents have continued to pursue appeals and other court options.

Most recently, on August 15, 2025, the U.S. Fourth Circuit Court of Appeals issued an order declaring that the pass-through prohibition of the law violated the First Amendment by prohibiting taxpayers from passing along the digital ad tax to consumers via surcharge or line-item fee.²² However, the case was simply remanded back to the U.S. District Court of Maryland and did not overturn the tax or raise concerns over it.²³ They could still be years away from a final resolution as opponents remain optimistic about their stance in the final outcomes, including those from tech industry giants such as Apple, Google, Facebook, and Peacock, who have challenged the law in four separate Maryland Tax Court cases.²⁴,²⁵

Not done yet, Maryland lawmakers also proposed a measure—House Bill 414 (2025)—that would have imposed a digital social media gross revenues tax on entities with more than one million active monthly users in the U.S. or that generate more than $500 million in annual gross revenues.²⁶ Derived from all revenues generated by a digital social media entity in the state, taxpayers would be assessed a rate of 5.0 percent if AGR is between $500 million and $1 billion, 7.5 percent if the AGR is more than $1 billion through $10 billion, and 10.0 percent if AGR exceeds $10 billion.²⁷

The bill would establish a Mental Health Care Fund for Children and Youth, with the proceeds going towards programs to improve access to mental healthcare services for minors in the state.²⁸ An accompanying fiscal note estimated revenues generated in the first full year of the tax could reach up to $30 million and generate up to $50 million by year four.²⁹ Ultimately, the measure has yet to make it out of committee, and it remains to be seen whether Maryland lawmakers will continue pursuit of this legislation in 2026 and beyond.

A Growing User Base: Other State Efforts

Arkansas

During the 2021 legislative session, lawmakers debated Senate Bill 558 (2021), which would have added a user tax to social media platforms. Specifically, the proposal would have levied a tax of 7 percent of gross revenue, plus $1 for the average number of account holders in the state during a calendar year.³⁰

Social media providers who operate or maintain a public social media platform with 500,000 or more Arkansas account holders, annual gross advertising revenues of at least $500,000, and “economic benefits from using residents’ data” would face this levy. Ninety percent of revenue would be dedicated to rural broadband development and 10 percent to addressing cybercrimes against children.³¹

The bill failed to make it out of committee and was referred for a possible interim study.³²

California

In an effort to fund a proposed Social Media Safety Trust Fund, administered by the State Treasury to support social media protections for minor children and mental health supports, lawmakers in California filed Assembly Bill 796 (2025). The measure, which stalled and will be brought up again in 2026, would have taxed social media advertising at an unspecified rate from 2026 to 2031. The rate, to be determined by the General Assembly, would have been levied on the annual gross receipts derived from social media advertisements in the state.³³

Uniquely, the measure would have broadly defined an advertisement under the law as a “paid message or posting, including video, text, illustration, or audio, which is rendered in exchange for consideration and is disseminated by a social media platform provider by means of a social media platform in any manner, for the purpose of inducing, or which is likely to induce, directly or indirectly, the purchase of a commercial product or service.”³⁴ Opponents argued that this could then apply to influencers and any other individual who receives any compensation for a post that can be construed as an ad for goods or services.³⁵

Connecticut

Soon after Maryland, lawmakers in the Nutmeg State introduced several proposals during the 2021 legislative session, which failed to gain traction. House Bill 6187 (2021)—filed with a companion bill in the Senate—would have levied a 10 percent tax on the gross annual revenues derived from digital advertising services in the state for entities with worldwide gross revenues greater than $10 billion.³⁶

The proposal would have used the revenues to provide one-time relief funds of $500 to individuals, with the remainder supporting the state’s unemployment compensation fund due to unexpected strain during the COVID-19 pandemic. The bill died without being voted out of committee.³⁷

A separate proposal in 2021, House Bill 5645, would have added a to-be-determined tax based on apportioned annual gross revenue derived from social media advertising in the state. Any revenues would be dedicated to online bullying prevention, training, and research for school counselors on social isolation and suicide prevention. However, it died without passage upon sine die.³⁸

TABLE 1. Graduated Gross Excise Tax Rates for Digital Advertising Services proposed in Conn. HB 6443 (2021)

Gross Revenues for Digital Advertising	Tax Rate
Greater than $15 billion	10.0%
Between $5 billion and $15 billion	7.5%
Between $1 billion and $5 billion	5.0%
Between $100 million and $1 billion	2.5%

Additionally, a graduated gross excise tax on digital advertising was included in an initial form of the omnibus budget bill—House Bill 6443—to fund a new Connecticut Equitable Investment Fund. Eventually written out of the final bill’s language, it would have tasked the state Revenue Commissioner to adopt regulations for reporting and estimating tax payment requirements with varied rates based on the assessable base—or the annual gross revenues derived from digital advertising services in the state. Per an accompanying fiscal note, the new tax would have generated $75 million in revenues in Fiscal Year 2022, $162 million in FY 2023, $175 million in FY 2024, $188 million in FY 2025, and up to $201 million in FY 2026.⁴⁰

More recently, lawmakers revisited the issue with House Bill 5673 (2023), which died without being heard in a committee. The bill would have established a flat 10 percent tax on the annual gross revenues of any business with global gross yearly revenues exceeding $10 billion derived from digital advertising services.⁴¹

Hawaii

In 2025, lawmakers proposed House Bill 1458, which would have directed the state Department of Taxation to apply the state’s corporate income tax to advertising revenues earned by major social media platforms.⁴² The affected platforms were defined as those featuring more than 1 million active U.S. users and primarily earning revenues from advertising and collecting data to interact with users within the state or who use a state IP address. Funds would have been allocated to the state’s Broadband and Digital Equity Special Fund to support local journalism sources and fund initiatives to expand broadband or high-speed internet access.⁴³

Indiana

Hoosier State lawmakers also featured debate during the 2021 session regarding a measure that would tax social media platforms with 1 million or more Indiana accountholders, annual gross revenues of at least $1 million related to advertising in the state, and benefits from using the state’s Hoosiers’ data.⁴⁴ The rate would be 7 percent of gross revenue, plus $1 for the average number of account holders in the state during a calendar year. Revenues would be disbursed with 90 percent to the Rural Broadband Fund and 10 percent to a Cyberbullying, Social Isolation, and Suicide Prevention Fund.⁴⁵

While the bill died in committee, a Fiscal Note attached to House Bill 1312 (2021) estimated the social media surcharge and account holders surcharge could yield combined revenues of $60 to $118.3 million in Fiscal Year 2023.⁴⁶ An identical proposal, Senate Bill 372 (2022), was included in a broader-reaching omnibus tax cut bill the following year. It included a Fiscal Note that estimated revenues of $63.4 to $133.2 million in fiscal year 2024 in combined revenues.⁴⁷

Identical measures were refiled in the House and Senate, respectively, during the 2023 and 2024 sessions, but both attempts failed to make it out of either chamber.⁴⁸,⁴⁹

Louisiana

House Bill 612 (2021) would have added a section to the existing tax code governing the sale of services to include the sales of digital advertising services rendered by an advertising business—such as an advertising agency, design firm, or broadcast media business—when digital advertising services are delivered into the state. Current law exempts advertising services from sales and use tax. The measure passed out of committee but failed to have its third reading on the House floor prior to sine die.⁵⁰

Massachusetts

Legislators in the Commonwealth filed a bill that would have levied a 6.25 percent excise tax on the annual gross revenue (AGR) from digital advertising services for providers with such revenue in the state. House Bill 4179 (2021) would have exempted the first $1 million in revenue from the tax each year. The measure did not receive a vote in committee but was set aside for study in the interim.⁵¹

An identical measure by the same author died without a vote and was set aside for interim study during the 2023 session.⁵²

TABLE 2. Comparison of Proposed Digital & Social Media Ad Tax Legislation in Massachusetts

Measure	Impact	Rate(s)
House Bill 3089 (2025)	It would levy an excise tax on advertisement services involving a digital interface on any entity with revenues exceeding $25 million from digital advertising services within the state. Proceeds would be directed to the Local Newspaper Trust Fund	5.00 percent
House Bill 3224 (2025)	It would levy an annual excise tax on gross revenue derived from digital advertising services provided to users with IP addresses in the Commonwealth. However, the first $1 million in revenue would be exempt.	6.25 percent
House Bill 3263 (2025)	Based upon gross revenues, it would assess a variable tax and require entities to file a return estimating revenues from digital advertising services and paying at least 25 percent of the estimated tax due and any unpaid balance from the prior return. The tax would only apply to those with annual gross revenues of more than $100,000 from digital advertising services to users in the state.	• 5.00 percent (AGR $50,000,000-$100,000,000) • 10.00 percent (AGR $100,000,001-$200,000,001) • 15.00 percent (AGR >$200,000,001)
Senate Bill 2004 (2025)	It would levy an excise tax on advertisement services involving a digital interface on any entity with revenues exceeding $25 million from digital advertising services within the state. Proceeds would be directed to the Local Newspaper Trust Fund (15 percent) and a Pre-K and After School Programs Trust (85 percent).	5.00 percent

A competing measure, House Bill 2894 (2021), would have implemented a flat 5 percent excise tax on entities that generate more than $25 million in revenues from digital advertising within the Commonwealth. The revenues would be allocated to the Local Newspaper Trust Fund to provide grants to newspapers with a principal place of business in Massachusetts and circulation of 50,000 or less on weekdays.⁵³

Currently, in the 2025 General Court, lawmakers are reviewing four distinct revised proposals to develop a digital advertising tax or study in the Commonwealth.

Montana

In 2021, lawmakers proposed levying a digital advertising tax on entities with a global AGR exceeding $25 million. House Bill 363 (2021) would have assessed a tax of 10 percent on all providers with banners, search engines, interstitials, and other comparable forms of advertisement on business conducted within the state using an assessable base format.⁵⁴

The assessed value would be based on a calculation of revenues from digital advertising services provided to IP users within the state compared to those nationwide, as follows:

Montana AGR / U.S. AGR × 10.0%= Digital Advertising Tax

The first $1 million in revenues would be exempted, and the tax proceeds would have been directed to the state’s General Fund with no specific use or purpose set aside in the legislation.⁵⁵

A second attempt, in 2025, via Senate Bill 192, containing identical language, failed to pass out of committee.⁵⁶ According to the accompanying fiscal note, this new tax would have generated revenues of $9.5 million in FY 2026, $48.1 million in FY 2027, $51.6 million in FY 2028, and $55 million in FY 2029.⁵⁷

New Mexico

Unlike the other states discussed in this report, New Mexico took a regulatory approach as its Department of Taxation and Revenue adopted updated rules governing its existing 4.9 percent Gross Receipts Tax Regulations, which already covered a broad array of services, including traditional advertising services, to ensure digital advertising services are not taxed unfairly compared to conventional forms of advertising.⁵⁸

The first new rule clarifies that the tax applies to receipts of digital platform providers earned from selling digital advertising services where the digital platform may be accessed and viewed within New Mexico. It also defined devices, digital advertising services, digital platforms, and users for tax purposes.⁵⁹

The second part of the new administrative guidance applies to how receipts are sourced by clarifying that the reporting location is the business location of the digital platform provider. Given the impracticalities of tracking the precise locations of all platform users, digital platform providers can instead use the transmission location for reporting purposes, including data centers and the like.⁶⁰

New York

Lawmakers in the Empire State filed Senate Bill 5551 (2023), which would have assessed a 7 percent tax on revenue derived from advertising in the state on platforms with digital advertising revenues exceeding $100 million. The assessable base, calculated by dividing AGR in the state by AGR nationwide, would have been taxed at 7.0 percent with funds allocated to the general fund.⁶¹ The measure, which died in committee, was identical to measures proposed in the 2020 and 2022 sessions.⁶²,⁶³

More recently, during the 2025 legislative session, lawmakers renewed this tax debate via two paired measures—Assembly Bill 7805 and Senate Bill 4778.⁶⁴,⁶⁵ The measures, identical to the prior attempts, would have assessed a flat 7.0 percent excise tax on annual gross revenues derived from digital advertising services in the state of New York exceeding $100 million.⁶⁶

A second, competing proposal—Senate Bill 173 (2025)—would have levied a variable rate ranging from 2.5 percent to 10 percent based on the AGR of entities providing digital advertising services in the state.⁶⁷ Entities with global AGR of $100 million to $5 billion would be taxed at 2.5 percent, those with AGR of more than $1 billion up to $5 billion would be taxed at 5.0 percent, a 7.5 percent levy would be assessed on those with AGR of greater than $5 billion up to $15 billion, and a final tier of 10.0 percent would be taxed on those with AGR exceeding $15 billion annually. The measure failed to make it out of committee. Still, it would have dedicated revenues from this tax to support an unemployment bridge program for workers who do not qualify for unemployment insurance or other benefits.⁶⁸

Pennsylvania

A proposal in the Keystone State, currently pending in committee, would amend the state’s existing gross receipts tax to apply to digital advertising services. House Bill 1678 (2025) would impose a digital advertising services tax of 45 mills plus a five-mill surtax on each dollar of gross receipts from these services provided within Pennsylvania. Exempting broadcast and news media entities, it would define digital advertisements as those displayed on digital interfaces, including websites, platforms, and applications, to users within the Commonwealth via banner advertisements, search engine advertising, and interstitial advertisements utilizing personal consumer information.⁶⁹

Rhode Island

As part of the general appropriations act, House Bill 5076 (2025), Rhode Island lawmakers initially proposed a digital advertising gross revenue tax to begin on January 1, 2026.⁷⁰ While ultimately removed from the final amended version of the bill, the language would have imposed a tax of 10 percent of the assessable base of a taxpayer with annual gross revenues exceeding $1 billion or more. The assessable base would have been calculated as the annual gross revenues in Rhode Island from advertising services in the form of banner advertising, search engine advertising, interstitial advertising, and other comparable advertising services.⁷¹

Tennessee

Volunteer State legislators proposed a data transaction privilege tax in Senate Bill 270 (2025), which would have been imposed on a taxpayer’s AGR derived from digital advertising services apportioned to Tennessee. The tax would be at a rate of 9.5 percent and would apply to those with an assessable base of $50 million or more in AGR.⁷²

The taxable base would be upon gross revenues derived from digital advertising services, including banner advertising, search engine advertising, interstitial advertising, and other comparable advertising services that use personal information about the people to whom the advertisements are being served, that are attributed to Tennesseans. Any revenues would have been allocated to fund a universal prekindergarten program in the state.⁷³

Texas

Two competing digital and social media advertising proposals were filed during the 2021 legislative session in Texas. The first would have assessed a graduated gross excise tax on providers with banners, search engines, interstitials, and other comparable forms of advertisement, which would be assessed a variable rate from 2.5 percent of gross revenues derived in the state for entities with global gross revenues between $100 million and $1 billion and 10 percent for global revenues greater than $15 billion. The tax revenue would have been distributed to the state’s General Fund (75 percent) and the Foundation School Fund (25 percent).⁷⁴ Ultimately, the measure died without a hearing in committee.

An alternative approach in the Senate, aimed primarily at myriad ways to reduce property tax liabilities, would have imposed a 6.25 percent sales tax on an expansive array of enumerated services. This sales tax base expansion would have included advertising services, including internet advertisements.⁷⁵

West Virginia

A 2021 proposal from the Mountain State, which died in committee, would have levied a variable gross excise tax on revenues from digital advertising services in the state, including, but not limited to, social media platforms.⁷⁶ The tax would range from 2.5 percent for entities with global gross revenues between $100 million and $1 billion, 5.0 percent for those with more than $1 billion up to $5 billion in global revenues, 7.5 percent for those with more than $5 billion up to $15 billion in global revenues, and 10.0 percent for those with global revenues greater than $15 billion. For entities with a West Virginia annual digital advertising services gross revenue of at least $1 million, the tax is applied on a calendar year basis with quarterly payments of 25 percent of the projected tax base due each quarter.⁷⁷

What About the South? Projecting Impacts in the South

FIGURE 5. State Share of U.S. GDP for Professional Services, as Percentage of U.S. Total (2024)

Using 2024 data from the U.S. Bureau of Economic Analysis, the CSG South region contributes more than 31 percent of the U.S. gross domestic product (GDP) for professional services, including marketing and advertising services, as part of the North American Industry Classification System (NAICS). Specifically, NAICS 5418 includes advertising and related services per the U.S. Bureau of Labor Statistics, which defines the “Professional, Scientific, and Technical Services” sector as comprising establishments that specialize in performing professional, scientific, and technical activities for others.⁷⁹

Montana, which featured one of the more detailed fiscal notes regarding its digital advertising tax proposal, provides a transferable template for merging industry data with state GDP to determine possible tax implications. For example, a state’s typical GDP share of the total U.S. GDP for an industry—in this case, advertising services—can be multiplied by the aforementioned industry-reported U.S. revenues of approximately $259 billion to calculate the estimated gross digital advertising revenue in each state.⁸⁰,⁸¹

Per research from the Montana fiscal note, approximately 90 percent of digital advertising revenue is generated by taxpayers with $25 million or more in global digital advertising revenues. This allows each state’s apportionment of digital advertising revenue to be multiplied by 90 percent to estimate the taxable revenue figure.⁸² While not exhaustive, these figures—when applied to the three-tiered rates proposed below—provide an informative estimate of state tax revenue in the South if states follow the path laid by Maryland and others to establish this new tax.

The formula to calculate possible state digital advertising revenues can be visualized as follows:

U.S. Digital Advertising Revenue ($) × State Share U.S.Professional and Digital Services GDP (%)=
Estimated State Digital Advertising Revenue ($)

(U.S. Digital Advertising Revenue×State Share U.S.Professional and Digital Services GDP)×90.0% =
Estimated State Taxable Digital Advertising Revenue ($)

TABLE 3. Estimated CSG South Member State Digital Advertising Revenues (FY 2024)

State	Estimated Share of U.S. Advertising GDP (%)	Estimated Gross Digital Advertising Revenue (millions)	Estimated Taxable Digital Advertising Revenue (millions)
Alabama	0.9	$2,331.000	$2,097.900
Arkansas	0.3	$777.000	$699.300
Florida	5.8	$15,022.000	$13,519.800
Georgia	2.7	$6,993.000	$6,293.700
Kentucky	0.6	$1,554.000	$1,398.600
Louisiana	0.7	$1,813.000	$1,631.700
Mississippi	0.2	$518.000	$466.200
Missouri	1.4	$3,626.000	$3,263.400
North Carolina	2.7	$6,993.000	$6,293.700
Oklahoma	0.5	$1,295.000	$1,165.500
South Carolina	0.9	$2,331.000	$2,097.900
Tennessee	1.5	$3,885.000	$3,496.500
Texas	8.7	$22,533.000	$20,279.700
Virginia	4.2	$10,878.000	$9,790.200
West Virginia	0.2	$518.000	$466.200
CSG South Total	31.3	$81,067.000	$72,960.300

Further, by examining proposals across the U.S., it appears many states considered flat or graduated tax rates of between 2.5 percent and 10 percent as part of their digital advertising tax proposals. Accordingly, by assessing the taxable revenues calculated in Table 3 at four theoretical tax rates—2.5, 5.0, 7.5, and 10.0 percent—it is possible to develop a rough estimate of the range of tax revenues a flat digital advertising tax could generate for states in the South. With so many Southern states considering reductions of personal or corporate income tax rates, expanding the tax base by treating digital advertisers at similar rates to other entities may provide support for filling significant revenue gaps due to income tax phase-outs.

Even states that have seen year-over-year declines in reliance upon income tax revenues, such as Georgia, still relied on individual income tax receipts for between 52.4 percent and 43.9 percent in FY 2022 and FY 2024, respectively, of total state receipts. Further, with more than $9 billion in FY 2024 sales and use tax revenues,⁸⁶ a new digital advertising services tax would not significantly contribute to replacing lost income tax receipts nor supplant existing primary drivers of sales tax revenues.

For example, using the estimates in Table 4, a digital ad tax of 2.5 percent would only contribute 1.7 percent of total sales and use tax receipts. A 10 percent digital ad levy would only represent 7.0 percent of existing FY 2024 sales and use tax revenues.⁸⁷ Nevertheless, significant reductions in one tax category would likely require consideration of myriad options—including a digital and social media advertising services tax—to replace lost revenues.

However, these gross tax revenues do not include any associated administrative, operational, or personnel costs, which will vary significantly per state. These costs could range from two additional full-time employees at a total cost for personnel, operational, and administrative expenses of $600,000 in year one, with recurring costs averaging $200,000 per year in a smaller state like Montana, to up to 0.5 percent of the tax revenues collected as estimated in Tennessee or nearly $1.6 million in Maryland to hire administrative and legal positions in relation to the new tax.⁸⁸,⁸⁹,⁹⁰

TABLE 4. Estimated CSG South Member State Digital Advertising Tax Revenues, in millions (FY 2024)

State	Estimated Digital Ad Tax Revenues (2.5%)	Estimated Digital Ad Tax Revenues (5.0%)	Estimated Digital Ad Tax Revenues (7.5%)	Estimated Digital Ad Tax Revenues (10.0%)
Alabama	$52.448	$104.895	$157.343	$209.790
Arkansas	$17.483	$34.965	$52.448	$69.930
Florida	$337.995	$675.990	$1,013.985	$1,351.980
Georgia	$157.343	$314.685	$472.028	$629.370
Kentucky	$34.965	$69.930	$104.895	$139.860
Louisiana	$40.793	$81.585	$122.378	$163.170
Mississippi	$11.655	$23.310	$34.965	$46.620
Missouri	$81.585	$163.170	$244.755	$326.340
North Carolina	$157.330	$314.685	$472.028	$629.370
Oklahoma	$29.138	$58.275	$87.413	$116.550
South Carolina	$52.448	$104.895	$157.343	$209.790
Tennessee	$87.413	$174.825	$262.238	$349.650
Texas	$506.993	$1,013.985	$1,520.978	$2,027.970
Virginia	$244.755	$489.510	$734.265	$979.020
West Virginia	$11.655	$23.310	$34.965	$46.620
CSG South Total	$1,824.999	$3,648.015	$5,472.023	$7,296.030

Not So Fast… Barriers to Adoption

While many proponents view the legality and spread of these digital and social media advertising taxes as a given, similar to the 2018 South Dakota v. Wayfair decision, in which the U.S. Supreme Court overturned the long-standing physical nexus requirement for internet commerce and online sales tax, the proposals face significant opposition and legal scrutiny.⁹³

The primary impetus for challenging these laws is from the Internet Tax Freedom Act (ITFA) of 1998. Opponents argue that the ITFA specifically prohibits states and localities from imposing discriminatory taxes on e-commerce, which it defines as “any transaction conducted over the internet or through internet access, comprising the sale, lease, license, offer or delivery of property, goods, services, or information, whether or not for consideration.”⁹⁴ As such, critics argue that these digital and social media advertising tax laws, since they would not apply to traditional advertising media, violate the ITFA’s anti-discrimination provisions.

However, as noted in this report, court rulings on the matter have been mixed, and the threat of an ITFA challenge has not entirely stymied state attempts to levy this new tax. Additionally, as seen in Maryland’s first-in-the-nation experience, years of litigation have led to interruptions to the tax levy, with a final resolution still to be determined. There is also the specter of having to refund the more than $419 million collected since 2022 if the law is repealed.⁹⁵

Another barrier, which has recently appeared in court challenges in Maryland, surrounds the concept of “pass-through” bans. Specifically, Maryland’s law prohibits businesses from notifying customers and subsequently passing on the tax cost to them in response to its digital and social media advertising tax. In an August 15, 2025 ruling, the Fourth Circuit of the U.S. Court of Appeals ruled that such a provision violated the First Amendment.⁹⁶

The ongoing debate over these bill provisions, parallel to the ongoing state Tax Court cases, illustrates the myriad barriers these proposals may face and the need for careful consideration when drafting such legislation.⁹⁷ With digital and social media advertising continuing to demand a growing share of the market, it is needless to say that there is significant support on both sides of the equation, and ultimately, the courts will decide whether these proposals are dead-on-arrival or represent an update of tax codes to comply with the realities of business in the 21st century.⁹⁸

---

Conclusion

With internet-based advertising and social media activity increasing year-over-year, while traditional forms of media and brick-and-mortar business services continue to decline, states risk falling further behind if they fail to consider this “changing of the guard”—particularly as e-commerce is changing with the advent of artificial intelligence and social media.⁹⁹,¹⁰⁰ However, given the Old Bay State’s ongoing legal problems, other states may wish to consider leaving out any pass-through prohibitions when drafting new digital and social media advertising tax policies.¹⁰¹ Further recognizing the changing landscape of advertising, marketing, and business writ large, some states have looked past the advertising debate and, instead, moved to examine how to levy taxes on data brokers or social media sites based on users or accounts.

Oregon, in 2021, first proposed a 5 percent gross receipts tax on revenues generated from data broker sales, which was defined as the sale of taxable personal information accumulated from internet-related activities from an individual using an in-state IP address.¹⁰² Likewise, Washington state debated a similar measure in 2021 and 2025, which would have expanded the state’s existing business and occupation tax to all entities engaging in the sale of personal data or exchanging personal data for other consideration.¹⁰³ The proposal would have taxed data brokers at 1.8 percent times the gross business revenues attributable to business activity in the state.¹⁰⁴

Alternatively, lawmakers in Minnesota instead proposed a measure to require social media companies to pay a monthly fee to the state based on the number of active Minnesota users or accounts on their platforms. Platforms would pay a graduated rate. Those with:

• 100,000 users or fewer would be exempt from the tax;
• 100,001 to 500,000 users would pay $0.10 per user per month;
• 500,001 to 1,000,000 users would pay $40,000 per month plus a user fee of $0.25 per user per month for each user over 500,000; and
• Platforms with more than 1 million users would pay a monthly fee of $165,000 plus a monthly user fee of $0.50 for every user over 1 million.

Legislative fiscal analysis estimated the bill could raise $137 million in FY 2027 from approximately 14 large social media platforms qualifying for this tax based on user numbers.¹⁰⁵ While these measures ultimately died in committee, it remains certain that in the rapidly changing business and services landscape, states will have to contend with how best to update or modernize outdated tax codes based on the “old ways” of doing business.

Based upon historical policies in industrial democracies, legal scholars have argued that policy consensus has typically been in favor of imposing excise—or “sin”—taxes on goods and services which may be deemed poor for individual or social health or on business actions that could be considered deleterious to national or state economies. To that end, as argued in a Network Law Review article last year by professors from the Massachusetts Institute of Technology, trends have shown that there is a need to tax or update policies to address digital and social media advertising and/or use, especially as an alternative to bans on social media, which run afoul of First Amendment considerations.¹⁰⁷

Time will tell if lawmakers in other states decide to move in this suggested direction, pivot to social media user fees, or target personal data brokers instead. Regardless, a continually evolving digital economy means this tax revolution will continue to be debated in 2026 and beyond.

FIGURE 6. Personal Data Users and Uses Ecosystem Representation

Internet Advertising Bureau (IAB) Glossary

Category	Description
Internet Advertising	Total Internet advertising comprises online television, digital music streaming, podcast, esports streaming, newspaper, consumer magazine, trade magazine advertising, non-broadcaster VOD, mobile AR advertising, in-app games advertising, and online radio (for North America only), which are also all included in their respective segments, as well as retail Internet advertising and pure-play Internet advertising revenue.
Internet Protocol (IP)	A set of rules and standards for addressing and routing the format of data sent over the internet or other networks.
TV Advertising	This segment comprises all TV advertising revenue, including broadcast and online. Broadcast television covers all advertising revenues from free-to-air networks (terrestrial) and pay-TV operators (multichannel). Online TV advertising consists of in-stream adverts and reflects revenues from pre-, mid-, and post-roll ads around TV content distributed by broadcaster-owned websites.
Music, Radio, and Podcasts	This segment comprises consumer spend on music, including both physical and digital recorded music and live music played at concerts, as well as revenue from live music sponsorship, but does not include revenue from merchandise or concessions at live music events. It also includes revenue from consumer spending on radio license fees (where applicable) and all advertising spending on radio stations and radio networks. Finally, it includes revenue from podcast advertising, defined as a piece of principally spoken-word recorded audio content delivered over the internet, excluding audiobooks, that can be downloaded or streamed. This segment includes both digital and non-digital revenue and revenue from consumer and advertising spending.
Newspaper and Consumer Magazines	This segment comprises revenue from circulation (consumer spend) and advertising in newspapers and magazines. It considers both physical print editions and digital editions. It includes all daily newspapers, including weekend editions and free dailies. Weekly newspapers are included in markets where data is available. This revenue is digital and non-digital from consumer and advertising spending.
Out-of-Home	The out-of-home (OOH) advertising market consists of advertisers spending on out-of-home media in public and semi-public spaces. OOH comprises total advertiser spending on all out-of-home media formats, and is split between physical and digital. Advertising spend is tracked as net of agency commissions, production costs, and discounts. Traditional physical out-of-home media includes billboards, street furniture (bus shelters, kiosks), transit displays (bus sides, taxi toppers), sports arena displays, and captive ad networks (in such venues as elevators). Digital OOH includes any out-of-home Internet-connected advertising media (e.g., smart billboards).
Business-to-Business	This segment covers business-to-business media, comprising business information, trade magazines, professional books, and trade shows.
Video Games and Esports	This segment comprises consumer spending on video game software and services (not hardware or devices) across both traditional and social/casual gaming, as well as revenue from advertising via video games. It also includes revenue from consumers and advertisers spent on e-sport.

End Notes

1. Kurt Wagner, “Digital advertising in the U.S. is finally bigger than print and television,” Vox, February 20, 2019, https://www.vox.com/2019/2/20/18232433/digital-advertising-facebook-google-growth-tv-print-emarketer-2019.
2. CJ Bangah, et al., “Internet Advertising Revenue Report: Full-year 2024 results,” PwC/IAB, April 2025, https://www.iab.com/wp-content/uploads/2025/04/IAB_PwC-Internet-Ad-Revenue-Report-Full-Year-2024.pdf.
3. “Online advertising revenue in the United States from 2000 to 2024,” Statista, released April 2025, https://www.statista.com/statistics/183816/us-online-advertising-revenue-since-2000/.
4. Maryland House Bill 732 (2020), https://mgaleg.maryland.gov/mgawebsite/Legislation/Details/HB0732?ys=2020RS.
5. “Internet Advertising Revenue Report: Full-year 2024 results,” PwC/IAB, April 2025.
6. Brian Frosh, “Letter to Governor Larry Hogan,” The Attorney General of Maryland, April 22, 2020, https://mgaleg.maryland.gov/2020RS/ag_letters/hb0732.pdf.
7. Md. HB 732 (2020).
8. Brian Frosh, “Letter to Governor Larry Hogan.”
9. Md. SB 787 (2021).
10. Md. Code, General Tax § 7.5-101, https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gtg&section=7.5-101&enactments=true.
11. § 7.5-102.
12. § 7.5-103.
13. Md. HB 732 (2020).
14. Robert Rehrmann and Michael Sanelli, “Fiscal and Policy Note – Amended,” Department of Legislative Services, Maryland General Assembly, April 7, 2020, https://mgaleg.maryland.gov/2020RS/fnotes/bil_0002/hb0732.pdf.
15. Nancy Kuhn, “Legal Alert: Update on Maryland’s Digital Advertising Sales Tax,” Shulman Rogers, February 14, 2025, https://www.shulmanrogers.com/client-alert-update-on-marylands-digital-advertising-sales-tax/.
16. Ibid.
17. Brian Frosh, “Letter to Governor Larry Hogan.”
18. Deborah Bierbaum, Harley Duncan, and Jonathan White, “Internet Tax Freedom Act Talk Story,” Presentation at the Uniformity Committee Meeting of the Multistate Tax Commission in Little Rock, Arkansas, November 15, 2022, https://www.mtc.gov/wp-content/uploads/2023/02/ITFA-slides-Little-Rock-2022-Final.pdf.
19. Ibid.
20. Bryan Sears, “Federal judge dismisses First Amendment challenge to digital ad tax,” Maryland Matters, July 12, 2024, https://marylandmatters.org/2024/07/12/federal-judge-dismisses-first-amendment-challenge-to-digital-ad-tax/.
21. Md. Comptroller v. Comcast of California, Maryland, Pennsylvania, Virginia, West Virginia, LLC, et al., No. 32, September Term (2022), https://www.courts.state.md.us/data/opinions/coa/2023/32a22.pdf.
22. Chamber of Commerce, et al. v. Lierman, U.S. Court of Appeals, 4th Circuit, August 15, 2025, https://www.uschamber.com/assets/documents/Opinion-Chamber-v.-Lierman-Fourth-Circuit.pdf.
23. Bryan Sears and William Ford, “Wright hits the road, Lierman hits short-term rentals, Freedom Caucus hits back, more notes,” Maryland Matters, August 20, 2025, https://marylandmatters.org/2025/08/20/wright-hits-the-road-lierman-hits-short-term-rentals-freedom-caucus-hits-back-more-notes/.
24. Michael Bologna, “Tech Attorneys Expect Maryland Digital Ad Tax Demise,” Bloomberg Law, July 10, 2024, https://www.bloomberglaw.com/bloomberglawnews/daily-tax-report-state/XDV83S8000000?bna_news_filter=daily-tax-report-state#jcite.
25. Perry Cooper, “Peacock Attacks Last Minute Bulletin at Maryland Ad Tax Trial,” Bloomberg Law, July 31, 2025, https://www.bloomberglaw.com/product/blaw/bloomberglawnews/daily-tax-report-state/XCE4Q54O000000.
26. Md. HB 414 (2025), https://mgaleg.maryland.gov/2025RS/bills/hb/hb0414F.pdf.
27. Ibid.
28. Ibid.
29. Michael Sanelli, “Fiscal and Policy Note – First Reader,” Department of Legislative Services, Maryland General Assembly, January 29, 2025, https://mgaleg.maryland.gov/2025RS/fnotes/bil_0004/hb0414.pdf.
30. Arkansas Senate Bill 558 (2021), https://www.arkleg.state.ar.us/Bills/Detail?ddBienniumSession=2021%2F2021R&measureno=SB558.
31. Ibid.
32. Ark. Interim Study Proposal 81 (2021), https://arkleg.state.ar.us/Home/FTPDocument?path=%2FAssembly%2FInterim+Study+Proposal+and+Resolution%2FISP-2021-081.pdf.
33. California Assembly Bill 796 (2025), https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB796.
34. Ibid.
35. Peter Blocker, “Opposition to AB 796,” California Taxpayers Association, April 14, 2025.
36. Connecticut House Bill 6187 (2021), https://www.cga.ct.gov/2021/TOB/H/PDF/2021HB-06187-R00-HB.PDF.
37. Ibid.
38. Conn. HB 5645 (2021), https://www.cga.ct.gov/2021/TOB/H/PDF/2021HB-05645-R00-HB.PDF.
39. Conn. HB 6443 (2021), https://www.cga.ct.gov/2021/TOB/H/PDF/2021HB-06443-R01-HB.PDF.
40. “Fiscal Note: sHB-6443,” Office of Fiscal Analysis, Connecticut General Assembly (2021), https://www.cga.ct.gov/2021/FN/PDF/2021HB-06443-R000638-FN.PDF.
41. Conn. HB 5673 (2023), https://www.cga.ct.gov/2023/TOB/H/PDF/2023HB-05673-R00-HB.PDF.
42. Hawaii House Bill 1458 (2025), https://www.capitol.hawaii.gov/sessions/session2025/bills/HB1458_.HTM.
43. Ibid.
44. Indiana House Bill 1312 (2021), https://iga.in.gov/pdf-documents/122/2021/house/bills/HB1312/HB1312.01.INTR.pdf.
45. Ibid.
46. Randhir Jha, “Fiscal Impact Statement – LS7408,” Office of Fiscal and Management Analysis, Legislative Services Agency, January 5, 2021, https://iga.in.gov/pdf-documents/122/2021/house/bills/HB1312/fiscal-notes/HB1312.01.INTR.FN001.pdf.
47. Ind. SB 372 (2022), https://iga.in.gov/pdf-documents/122/2022/senate/bills/SB0372/SB0372.01.INTR.pdf.
48. Ind. HB 1517 (2023), https://iga.in.gov/pdf-documents/123/2023/house/bills/HB1517/HB1517.01.INTR.pdf.
49. Nate Bodnar, “Fiscal Impact Statement – LS6901,” OFMA, LSA, January 13, 2023, https://iga.in.gov/pdf-documents/123/2023/house/bills/HB1517/fiscal-notes/HB1517.01.INTR.FN001.pdf.
50. Louisiana House Bill 612 (2021), https://iga.in.gov/pdf-documents/123/2023/house/bills/HB1517/fiscal-notes/HB1517.01.INTR.FN001.pdf.
51. Massachusetts House Bill 4179 (2021), https://malegislature.gov/Bills/192/H4179.
52. Mass. HB 2930 (2023), https://malegislature.gov/Bills/193/H2930.
53. Mass. HB 2894 (2021), https://malegislature.gov/Bills/192/H2894/House/Bill/Text.
54. Montana House Bill 363 (2021), https://archive.legmt.gov/bills/2021/HB0399/HB0363_1.pdf.
55. Ibid.
56. Mont. Senate Bill 192 (2025), https://bills.legmt.gov/#/laws/bill/2/LC1649.
57. “Fiscal Note 2027 Biennium: SB0192.01,” Governor’s Office of Budget and Program Planning, Mont., February 12, 2025.
58. Charlie Moore, “Press Release: Department finalizes new Gross Receipts Tax regulations,” New Mexico Taxation and Revenue Department, December 20, 2023, https://www.tax.newmexico.gov/wp-content/uploads/2023/12/Regulations-finalized-release.pdf.
59. New Mexico Administrative Code 3.2.213.13, https://www.srca.nm.gov/nmac/nmregister/xxxiv/3.2.213amend.html.
60. NMAC 3.1.4.13(C)(5)(e), https://www.srca.nm.gov/parts/title03/03.001.0004.html.
61. New York Senate Bill 5551 (2023), https://www.nysenate.gov/legislation/bills/2023/S5551.
62. N.Y. SB 8056A (2020), https://www.nysenate.gov/legislation/bills/2019/S8056.
63. N.Y. SB 1124 (2022), https://www.nysenate.gov/legislation/bills/2021/S1124.
64. N.Y. SB 4778 (2025), https://www.nysenate.gov/legislation/bills/2025/S4778.
65. N.Y. AB 7805 (2025), https://www.nysenate.gov/legislation/bills/2025/A7805.
66. Ibid.
67. N.Y. SB 173 (2025), https://www.nysenate.gov/legislation/bills/2025/S173.
68. Ibid.
69. Pennsylvania House Bill 1678 (2025), https://www.palegis.us/legislation/bills/2025/hb1678.
70. Rhode Island House Bill 5076 (2025), https://webserver.rilegislature.gov/BillText/BillText25/HouseText25/H5076.pdf.
71. Ibid.
72. Tennessee Senate Bill 270 (2025), https://wapp.capitol.tn.gov/apps/BillInfo/Default.aspx?BillNumber=SB0270.
73. Ibid.
74. Texas House Bill 4467 (2021), https://capitol.texas.gov/tlodocs/87R/billtext/html/HB04467I.htm.
75. Tex. SB 1711 (2021), https://capitol.texas.gov/tlodocs/87R/billtext/html/SB01711I.HTM.
76. West Virginia Senate Bill 605 (2021).
77. Ibid.
78. “SAGDP2 Gross domestic product (GDP) by state,” U.S. Bureau of Economic Analysis, accessed August 25, 2025, https://apps.bea.gov/itable/.
79. “Professional, Scientific, and Technical Services: NAICS 54,” Industries at a Glance, U.S. Bureau of Labor Statistics, accessed August 25, 2025, https://www.bls.gov/iag/tgs/iag54.htm.
80. “Fiscal Note 2027 Biennium: SB0192.01,” Mont.
81. “Internet Advertising Revenue Report: Full-year 2024 results,” PwC/IAB, April 2025.
82. “Fiscal Note 2027 Biennium: SB0192.01,” Mont.
83. “SAGDP2 Gross domestic product (GDP) by state,” U.S. BEA.
84. “Internet Advertising Revenue Report: Full-year 2024 results,” PwC/IAB, April 2025.
85. “Fiscal Note 2027 Biennium: SB0192.01,” Mont.
86. Tyler Reinagel, “State Revenue, Rate, and Exemption Comparisons – Georgia, Florida, Tennessee,” CSG South, August 22, 2025.
87. Ibid.
88. Ibid.
89. Bojan Savic, “HB 218-SB270 Fiscal Note,” Fiscal Review Committee, Tennessee General Assembly, March 15, 2025, https://www.capitol.tn.gov/Bills/114/Fiscal/HB0218.pdf.
90. Rehrmann and Sanelli, “Fiscal and Policy Note – Amended.”
91. “SAGDP2 Gross domestic product (GDP) by state,” U.S. BEA.
92. “Internet Advertising Revenue Report: Full-year 2024 results,” PwC/IAB, April 2025.
93. Jennifer W. Jensen, et al., “South Dakota v. Wayfair – five years later,” PwC SALT Tax Insights, June 21, 2023, https://www.pwc.com/us/en/services/tax/assets/pwc-salt-tax-insight-wayfair-5-years-later.pdf.
94. 47 U.S.C. § 1105(2)(A)(i), https://www.govinfo.gov/content/pkg/USCODE-2020-title47/html/USCODE-2020-title47.htm.
95. Bryan P. Sears, “Judge strikes down provision of digital ad tax as First Amendment violation,” Maryland Matters, October 17, 2025, https://marylandmatters.org/2025/10/17/judget-strikes-down-provision-of-digital-ad-tax-as-first-amendment-violation/.
96. Chamber of Commerce et al. v. Lierman, Case No. 24-1727 (4th Cir. Aug. 15, 2025), https://law.justia.com/cases/federal/appellate-courts/ca4/24-1727/24-1727-2025-08-15.html.
97. Stephen P. Kranz, et al., “Fourth Circuit strikes down Maryland’s digital ad tax ‘pass-through’ ban,“ Inside SALT, August 19, 2025, https://www.insidesalt.com/2025/08/fourth-circuit-strikes-down-marylands-digital-ad-tax-pass-through-ban/.
98. Maria Koklanaris, “States’ Digital Ad Tax Pursuits Continue Despite Pushback,” Law360 Tax Authority, October 7, 2025, https://www.law360.com/tax-authority/state-local/articles/2396788.
99. Ibid.
100. “DHL’s E-Commerce Trends Report 2025: AI and social media reshaping online shopping,” DHL Group, June 4, 2025, https://group.dhl.com/en/media-relations/press-releases/2025/dhl-e-commerce-trends-report-2025.html.
101. Nancy Kuhn, “Legal Alert: Update on Maryland’s Digital Advertising Sales Tax.”
102. Oregon House Bill 2392 (2021), https://olis.oregonlegislature.gov/liz/2021R1/Downloads/MeasureAnalysisDocument/54570.
103. Washington Senate Bill 5799 (2025), https://app.leg.wa.gov/billsummary?BillNumber=5799&Year=2025&Initiative=False.
104. Washington House Bill 1303 (2021), https://lawfilesext.leg.wa.gov/biennium/2021-22/Pdf/Bills/House Bills/1303.pdf.
105. Minnesota Senate File 3197 (2025), https://www.revisor.mn.gov/bills/bill.php?b=senate&f=SF3197&ssn=0&y=2025.
106. “Personal Data Ecosystem,” Exploring Privacy Roundtable Series, Federal Trade Commission, 2010, https://www.ftc.gov/sites/default/files/documents/public_events/exploring-privacy-roundtable-series/personaldataecosystem.pdf.
107. Daron Acemoglu and Simon Johnson, “The Urgent Need to Tax Digital Advertising,” Network Law Review, March 25, 2024, https://www.networklawreview.org/acemoglu-johnson/.