Table of Contents
Let's Fix the Tax Treaty! mission is concerned with the large and diverse number of stakeholders impacted by the USG's practices of Citizenship Based Taxation. These stakeholders consist of
- US citizens living in Australia, many of whom are dual citizens who have permanently immigrated
- Children born while their Australian parents were living in the US (see this comment for argument that citizenship is not automatic)
- Australians who have acquired US Citizenship or Green Cards and have returned home
- Children to the above who may also be considered US Persons as a result of their parentage
- Australians currently living within the US
- Australian citizen spouses of any of the above
- This stakeholder group is estimated to number ~200,000 persons. See Numbers, stakeholders entry for basis of estimates on the size of this group.
Accurately estimating Stakeholder numbers is not possible given stakeholder group diversity and the lack of a consistent measurement process (single census, etc). The purpose of this page is to provide a best estimate and to document the factual basis behind this estimate.
Further documented information required
The best estimate of the total number of Stakeholders is in excess of 200,000 persons.
This number is believed reasonable based from the following:
- 90,100 USA-born Australian residents per the 2011 Australian Census, up from 71,718 persons in the 2006 census.1)
- Note that updated 2016 census information should eventually be available and it is expected to show further grow in numbers of USA born Australian residents.
- QuickStats on the ABS website contains a wealth of information about US-born Australian residents.
- 2016 data should be available in November 2017. Here's where to look (last checked 26/11/17).
- Annual estimates are available here. The 2016 estimate is 104,310 Australian residents born in the US.
- 80,499 +/- 2477 Australian-born residents of the USA as estimated by the US Census Bureau in 2015 2)
- Remainder made up of other stakeholders such as Australians who acquired US citizenship and returned home, green card holders and other nationalities who acquired US citizenship and then moved to Australia.
US State Department Estimates
As of 2011, The US State Department estimated 102,800 persons of USA Origin were residents within Australia 3). Note that the US state Department ceased providing individual country estimates in 2011 and this information is no longer posted on their website.
UN Census Data
Heitor David Pinto independently estimated the number of Americans living in countries outside the US4), including Australia, based on census data from other countries (mostly compiled by the UN).
His latest update estimates approximately a total of 185,000 American citizens resident in Australia comprised of roughly 104,000 American-born Australian residents and 81,000 American citizens by descent, which is a subset of Stakeholders and does not include Green Card holders, naturalised US citizens who now reside in Australia or Australians living in the US. This Facebook post (in FTT closed group) explains his methodology as applied to Australia.
The economic impact of US taxation of Australian residents is poorly documented. Here's what we do know:
In 2015, there were 751,180 US returns filed from outside the 50 US states (this includes US military stationed overseas and returns from Puerto Rico with non-Puerto Rico source income). These returns included 1,435,830 personal exemptions, which is a good indicator for the number of the 7+ million non-resident US citizens who were compliant with their US tax filings - about 20%. (data sourced from this excel file, available on the IRS website).
The IRS website also contains data on 2011 filers with either Form 2555 (Foreign Earned Income Exclusion) or Form 1116 (Foreign Tax Credit). This data (excel file) shows that 721,330 US taxpayers claimed a credit for US$19.4 billion in foreign tax paid on “Other Income”. A file (excel file) with foreign taxes broken down by country shows that 22,391 US returns claimed credit for an aggregate of US$598 million of Australian tax on US$2.7 billion of Australian source income. The Australian tax claimed as a credit on US tax returns relates to the following income categories:
|Income Category||Australian Tax|
In addition, the data (excel file) shows 10,353 US returns filed in 2011 with Form 2555 claiming an exclusion for US$707 million of earned income from Australia. Total foreign earned income on these returns is US$1,444 million. These returns may also include Foreign Tax Credits, so some will be included in the numbers above.