Notes from the Field — August 3, 2026
Delegates in New York are negotiating this week to fix a system built, deliberately, without them in the room.
This week, delegates from around the world are in New York negotiating a UN Framework Convention on International Tax Cooperation — an attempt to fix a system that lets multinational corporations shift profits into accounting shells and pay tax nowhere at all. The occasion for the negotiation is the argument economist Jayati Ghosh made in an August 3 opinion piece: as she put it, for decades, multinational corporations have been shifting profits out of the countries where they are generated into accounting “nowhere” zones, and the UN convention represents a chance to link profits back to the places that actually produced them. Project Syndicate
That’s her read, and it’s worth being clear it’s a read, not a settled finding — but the facts underneath it are independently documented. The rules multinationals exploit weren’t accidents. They were built at the OECD, a forum of wealthy nations, over decades, without the countries losing the most revenue in the room. The United States enacted a corporate alternative minimum tax in 2022, but it has since been diluted. The same is true of the global minimum corporate tax adopted under the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting, whose planned reallocation of taxing rights from headquarters to market countries has stalled. Project Syndicate
This is Public Investment, Private Capture’s arrow with a different instrument: ask what was set once, in a room the public didn’t control, and never revisited — no matter how much value it went on to produce. TNG Essay 11 documented the domestic version of this sequence, repeating across a century of American industries where officials defending the arrangement believed their own account because the alternative sat outside a frame their funders built. The international tax architecture is the same sequence at a different scale: the room that wrote the rules was never required to go back and check whether they still served anyone but the people who’d built them.
The frame most coverage of this week’s negotiations will use is hopeful: a historic UN treaty, decades in the making, finally under negotiation. What that frame leaves out is the room’s own recent record. The corporate minimum tax that was supposed to close this exact gap already exists, and it’s already been diluted. The OECD framework was supposed to reallocate taxing rights toward the countries where profits are actually made, and that reallocation has already stalled. A convention negotiated this week doesn’t automatically escape the fate of the mechanisms that came before it — it enters a system where the room that built the original rules is still in the building.
The tool changed with the century. The problem being solved did not.
The Legal Frame — Broken Frames (Public Investment, Private Capture)
Origin case: TNG Essay 11 — Out of Frame
Copyright 2026 — Steve Sagnotti
Sources: Jayati Ghosh, “The Case for a Pay-Where-You-Play Tax System,” Project Syndicate, August 3, 2026. Zorka Milin, “Global Tax Reform Is the Key to a Fair AI Economy,” Project Syndicate, August 2026, on the status of the OECD minimum-tax and Pillar One reallocation.
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