This article contrasts three approaches to dealing with the BEPS problem: adopting a unitary taxation regime, ending deferral, and adopting anti-base-erosion measures. It concludes that while the first approach is the best long-term option, the other two are more promising as immediate candidates for adoption in the context of U.S. tax reform and the OECD BEPS project.
Avi-Yonah, Reuven S. "Tax, Trade and Harmful Tax Competition: Reflections on the FSC Controversy (Foreign Sales Corporations)." Tax Notes Int'l 21, no. 25 (2000): 2841-5.