CEOs love borderless talent until they realize that it exposes them to borderless corporate income taxation...
This isn't like the old days when Apple and Microsoft could exploit international tax loopholes. Those loopholes are gone, and transfer pricing (aka mandatory profit for related-party cross-board transactions) is now mandatory. In some countries, there are proposals to to tax transfer pricing income even if the entity as a whole is not profitable, and this is on the table for the next OECD guidelines. Countries are also no longer willing to accept the ridiculous under-valuations of migrated or licensed IP that Apple and Microsoft got away with.
This isn't like the old days when Apple and Microsoft could exploit international tax loopholes. Those loopholes are gone, and transfer pricing (aka mandatory profit for related-party cross-board transactions) is now mandatory. In some countries, there are proposals to to tax transfer pricing income even if the entity as a whole is not profitable, and this is on the table for the next OECD guidelines. Countries are also no longer willing to accept the ridiculous under-valuations of migrated or licensed IP that Apple and Microsoft got away with.