The United States is the only developed country to practice a system of extraterritorial taxation that treats the tax residents of other countries as simultaneously subject to U.S. worldwide taxation based on citizenship. This extraterritorial tax system is a separate and more punitive tax...

This article explains the simple regulatory actions that United States Department of the Treasury can take that would, in the absence of legislative change, improve the lives of Americans living overseas and permit the IRS to better focus its limited resources to more effectively administer the...

While share buybacks in the classical perfect markets context are well understood, tax rules often distort the wealth transfer in non-obvious ways. Unique Australian tax rules for off-market share buybacks allow buyback participants to receive tax credits and reduced capital gains tax. These...

The uniquely American definition of “tax residency,” which includes the imposition of worldwide taxation on the tax residents of other countries, has delegated to the IRS the job of implementing three separate and distinct tax systems: residence, source, and extraterritorial. Through its...

The United States is unique in taxing non-resident citizens under the same rules as residents. For Australian citizens and residents who are also US taxpayers, the impact of this is much greater than the generally minimal amount of US tax due each year. The US grants citizenship broadly and...

Purpose The purpose of this paper is to theoretically and empirically analyze the impact of the types of micro-innovation on innovation performance and the choice of micro-innovation strategies in different contexts on the basis of an examination of the basis and standards of micro-innovation...