A taxonincome frombusinessandoccupationswas not a directtax and could be subjected to taxation without the necessity ofapportionment on the basisof population.
Formula apportionment would allow tax bureaucrats to concoct a system for arbitrarily changing the existing distribution of business income, with a clear goal of forcing companies to over-state their taxable income in high-tax nations.
Formula apportionment appeals to governments with high corporate tax rates because it would increase their revenues, while jurisdictions with pro-growth policies would lose out.