Resources

The Resources section of the website is being replaced by a user-editable wiki.

The pages that were previously linked in the Resources menu can be found here:


This page contains links to the source documents. For analysis of the documents see the sub-pages accessible from the top menu.

The Current Australia/US Double Tax Agreement:

Model Tax Treaties:

The Australian FATCA Intergovernmental Agreement (IGA):

Relevant academic papers on tax treaties, international taxation and/or FATCA:

  • Christians, Allison, Human Rights at the Borders of Tax Sovereignty  presented at NYU 13 Feb 2017 (commentary) – see comment below.
  • Christians, Allison, When Parliament Sleeps: Tax Treaty Practice in Canada   (May 17, 2016). 10 J. Parl. & Political L. 15 (2016). Available at  SSRN / Additional data at Isaac Brock – while this paper is not analysis of the treaty itself, it discusses problems with the process of amending or re-negotiating a tax treaty based on Canadian experience.
  • Shaviro, Daniel, Taxing Potential Community Members’ Foreign Source Income (July 1, 2015). NYU Law and Economics Research Paper No. 15-09. Available at SSRN

Other useful websites are listed here.

If you would like to add additional resources, leave a link in the comments.

1 thought on “Resources”

  1. I have added a list of academic papers to the bottom of this page. If you know of any others that should be included, please leave a comment.

    The paper by Allison Christians on Human Rights at the Borders of Tax Sovereignty is quite interesting (there’s a link to the paper above). The first part of the paper explores the philosophical justifications of a government’s right to tax. These justifications are then examined with respect to citizenship taxation and the taxation of multinational corporations.

    I found the comparison with California’s Worldwide Unitary Tax quite interesting. Non-resident US taxpayers not getting anywhere because they have no political power – not in the US where they’re spread across every congressional district – and not in their home countries where they are a small minority and similarly dispersed. Business interests have much more power – which is why so many countries passed the FATCA IGAs as quickly as they could. The conclusion seems to be that non-resident US taxpayers are more likely to find relief in the courts than from the legislature (either in the US or where they live).

    A blog post about this article by Dan Shaviro at NYU makes the interesting observation:

    To say you are a U.S. person, e.g., by reason of your citizenship, is to say: You are still one of us. We still care about you. But the direct practical consequence is that, if you’re still one of us and thus we still care about you, we respond by imposing continuing U.S. tax burdens on you – whereas if we don’t care about you we DON’T impose those burdens. Talk about tough love!

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