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" ... Note that governments outside the OECD club (e.g., Brazil, China, India) were never sold on the international consensus in the first place. They are amused by our clinginess to jurisdictional tax principles that no longer mesh with reality or adequately protect the public fisc. One has to wonder if the next great paradigm shift in global tax policy will emanate from their ranks, not ours. If so, it’s likely to bear little resemblance to BEPS. ... "
" ... You could even set those up where one-third of the tax base is determined by your investments in property, like whether you have a factory or not. The other third could be your people. How much payroll do you have? If you've got a jurisdiction that has 50 percent of your employees and they'd have 50 percent of your tax base for that segment of the formula. And then sales, you have to put sales in here. That's your classic three factors: sales, people, and property. The problem is that that did not have a clinginess. It didn't stick around long enough at the state level. ... "