I suppose a non-citizen subject to this tax would have to appeal to their own government and raise the issue diplomatically. But I doubt most nations would be in a position to change the United State's behavior in this regard. Maybe the EU has enough clout to contest this in a court of international law. But that also depends on them wanting to raise the issue in the first place.
The EU is literally in the process of putting the same kind of taxes on technology companies. And people are cheering for it. The US does the same in reverse, everyone loses their minds...
I don't think it's the same. Huge corporations already shift their profits around to avoid taxes. This is only going to affect small businesses and independent creators that can't take advantage of the same corporate structure as a huge tech company.