By David Elkins | Volume 9 | Issue 1 This Article examines the concept of location-specific rents (LSR) and its growing influence in international tax theory as a basis for allocating taxing rights among sovereign states. Although LSR has been praised as a fair and efficient framework for source-country taxation, critics contend that it is inherently unmeasurable and therefore impractical. This Article challenges that view by arguing that LSR can, in fact, be quantified with