So it's "only" a matter of deciding whether those taxes should be paid in US vs. other countries (and if the intellectual property was developped mostly in the US, it seems fair for the US to get most of it).
If you're opening a location in another country, and that location takes X in revenue, the tax should be paid in that country.
Why on earth do you think its fair for US based organizations to spread across the globe, reap the huge profits from that but funnel all the cash back into the US?
Random guess, they're American :-)
Facebook, Google & co. are absolutely ravaging local economies, pardon me, disrupting legacy economies all over the world and a small chunk of that ends up as compensation in the US.
The rest of that, FAANG are just sitting on it like a dragon hoarding gold, as far as I can see.
Absolutely no support or protection for local companies, Linux, etc.
Where is our Baidu, Samsung, Yandex, or Sony, etc.?
The whole continent is practically a vassal state of the US, under German administration.
(Other countries mostly have sales, that's what sales/vat are for)
If instead of being a digital company it was a physical good company, would it be so controversial? E.g. goods are designed/produced in Italy, shipped and sold abroad (as a start in totally independent shops). Who should book the profit? Usually that will be the manufacturer and the local foreign stores have a much smaller margin.
If now those shops are arm-length subsidiary, why should it be different?
Would end up with every digital company having to register in country before accepting any user from that country (with maybe a facilitated process where they can self declare their per-country revenue).
People already complain about the arbitrary geo-fencing, but that might indeed be inevitable.
It all hinges on how "location takes x in revenue" is defined.
The simplified version of how all these transfer pricing tax avoidance schemes work is this: The good is produced in Country X (e.g., US) then sold to a subsidiary in the tax haven Country Y (e.g., Ireland or some Caribbean Island) for just a tiny amount of profit over cost, and so they owe taxes to Country X on that de minimis profit. The subsidiary in Country Y then sells the good to Country Z (e.g., the rest of the world) for the retail price, and so they earn almost all their profit in Country Y and so pay taxes there, but it's a tax haven so the actual tax rate is minimal. Logic would dictate that the profit should be recognized in the jurisdiction where the good was produced or the one where it was sold to the end customer or some combination of both, but logic does not prevail when it comes to tax law.
In 10 years from now it could easily be China that owns many of these mega cooperation's. Would you find it fair if the tax money from china "MS", china "apple", china x all would go to China and the USA would get zero.
That was the main change of the TCJA, it stopped companies from doing the deferred taxation trick.