Yes it’s on SSRN here: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3132538 … I just haven’t had time to blog it yet, but will!
Plus the international (not tax related) politics of this. Developing countries have resisted social clauses in trade agreements. Guatemala successfully challenged the US on that case: https://www.ictsd.org/bridges-news/bridges/news/trade-dispute-panel-issues-ruling-in-us-guatemala-labour-law-case … - so why would they define majority of workforce as 'compelled'?
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I get that it reads to you as a policy proposal and you’re skeptical. But the question driving this analysis is not policy or politics. It is whether value creation is a useful legal principle for allocating MNC profits and if so, how the principle may be interpreted.
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That said I don’t disagree at all that politics and optics can easily get in the way of a paradigm shift.
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