"stateless income means profits earned in a country other than where the firm is headquartered and subject to tax only in a third country which imposes little or no tax."
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1875077
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1791769
"......fundamental thesis
the pervasive presence of stateless income tax planning changes everything. Stateless income privileges multinational firms over domestic ones by offering the former the prospect of capturing “tax rents” – low-risk inframarginal returns derived by moving income from high-tax foreign countries to low-tax ones. Other important implications of stateless income include the dissolution of any coherence to the concept of geographic source, the systematic bias towards offshore rather than domestic investment, the more surprising bias in favor of investment in high-tax foreign countries to provide the raw feedstock for the generation of low-tax foreign income in other countries, the erosion of the U.S. domestic tax base through debt-financed tax arbitrage, many instances of deadweight loss, and – essentially uniquely to the United States – the exacerbation of the lock-out phenomenon, under which the price that U.S. firms pay to enjoy the benefits of dramatically low foreign tax rates is the accumulation
of extraordinary amounts of earnings ($1 trillion or more, by the most recent estimates) and cash outside the United States."
Tax rents a go go !!!!
