[timr]

"The implied but never fully-articulated point of this article is that high-tax domiciles resent it when rational actors having a choice in the matter will routinely structure their business affairs to incur tax to the maximum extent possible in low-tax as opposed to high-tax domiciles."

No, that's the conclusion you might draw if you choose to read the article through an extremely narrow filter where you start from the premise that the laws, as they stand, are sufficient and reasonable.

If, instead, you look at the situation and wonder at the utter inefficiency of a tax system that allows some (but not all) corporations to move profits around on paper to avoid taxation -- but only if they spend money on creating fake offices and legal castles in the sky that don't contribute to productivity -- then you start to wonder if perhaps the situation can be changed. And that's an interesting discussion.

[notJim]

I don't think your point and the point you quoted are actually at odds.