The Inspiration Behind this Special Issue.

Abstract

Sol Picciotto is a living legend in the tax justice movement. Almost every single activist involved has heard of him and most likely read some of his work. I myself came across his writings almost immediately after joining the movement and was fortunate to meet him shortly afterwards.

Sol’s writings have the uncanny ability to go straight to the essence of the issue. Indeed, he is most famous for his consistent and prescient articulation of global formulary apportionment (GFA), which has today become the basis of the Two Pillar solution. GFA underlies profit allocation under Amount A and also the Under Taxed Payments Rule (UTPR) of the GLOBE Rules. This is directly the result of Sol’s ceaseless campaigning pointing out the deficiencies of the Arm’s Length Principle, and I for one am very glad that he is seeing his dream come true. As we all know, we are living through a historic period of reform in the international tax system, and this is only the beginning.