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Comment by ig1 | Hacker News Reader

You don't have to be in the US to be listed in the US, Atlassian are actually moving to the UK but listing in the US.

Exactly. This is all about corporate tax rates, capital gains, transfer pricing, etc.

Could you elaborate? It'd be interesting to know more.

I don't know about Australia's system, but the U.K. has been a popular target for reincorporation of American companies, along with Ireland and Switzerland: http://online.wsj.com/news/articles/SB1000087239639044423050.... Bermuda, a popular domicile in the past, apparently made certain changes to its tax code that caused companies to move to European countries.

For corporations, tax rates lead to domicile-shopping because finance analysts use Earnings per Share (EPS), which is computed after taxes, as a key measure of company performance. Relocating from somewhere in the U.S. to the U.K. might substantially increase the total taxes paid by employees and executives (almost every developed country has a higher individual tax burden than the U.S.), but it can goose that all-important EPS number.

Well part of the confusion is that one reason for our headline rate, as I understand it, is because we have franking for company/income tax.

So Australian companies tend to pay dividends much more freely than US companies, but the headline corporate tax rate is higher.

That's actually an interesting illustration of the dynamic. The management at publicly-listed companies are very preoccupied with what finance analysts have to say about the stock. When someone at Morgan Stanley compares two companies on an EPS basis, what's relevant is the rate paid by the company. It comes down to $0.28 per share versus $0.35 per share, even if other features of the tax code mitigate that difference when a dividend is actually paid out.

Right. I'm going on the article's assertion that relocating to the UK will make it easier to launch an IPO in a US market.

Tax would be a big part of that. I expect that American familiarity and comfort with UK companies would be another.

I also suspect the relative ease of relocating a large number Australian's to the UK would have a big impact (ease of getting visa's etc).

I think it's easier to get Australians into the USA on the E3 visa.

E3s are temporary and must be renewed every 2 years. Can't be transferred to another employer. Can't be used to qualify for permanent residency. They are quite useful if your married (straight) partner wants to join you (and somewhat useful if you have a defacto non-US citizen gay partner due to a bizarre quirk in the law. Tough luck if you have a defacto straight partner though.)

Lots of Australians would qualify for permanent residency in the UK under an Ancestory Visa, or an equivalent in another EU country. Emigrating AU<->UK is a very well worn path that's easy to naviagte. The US isn't quite so welcoming.

(Source: i'm an Australian who live in the UK for 10 years, the US for 2 and now Canada for 5.)

How would you compare the 4 countries, and why did you choose Canada as your current place?

I don't see any of those drawbacks as drawbacks, though. For me the key to the E3 is that I don't have to play H1B lotto.

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