That makes rents uncollectible, even if the U.S. tries
Garbarino ’15 [Carlo and Giulio Allevato; Summer 2015; Professor of Law at the Universita Bocconi, Grotius Research Scholar at the University of Michigan Law School, Hauser Global Visiting Faculty at the NYU Law School, Visiting Professor of Law at the University of Michigan Law School, Visiting Professor of Law at the University of Florida School of Law, Visiting Professor at the University of San Paulo, Visiting Scholar at the University of Michigan Law School, Visiting Professor at Sorbonne University, Paris, Visiting Scholar at Yale Law School; Assistant Professor of Tax Law at the SDA Bocconi School of Management, Ernst Mach Scholar at the Institute for Austrian and International Tax Law, Vienna University of Economics and Business, Ph.D. from the Universita Bocconi, International Tax, LL.M. from the University of Michigan Law School; Michigan Journal of International Law, “The Global Architecture of Financial Regulatory Taxes,” vol. 36]
Under the worldwide approach, a country unilaterally imposes an FTT on all of the transactions for securities issued in the country, regardless of the location of the transaction or place of establishment of the parties and the intermediaries. For example, in 1964, the U.K. enacted a type of FTT (the British Stamp Duty Reserve Tax) on the transfer of ownership of shares of companies established in the U.K., regardless of the location of the transaction and the establishment of the trader. 124
The worldwide FTT tends not to cause relocation effects, because transactions remain subject to the tax even if they are shifted abroad. In addition, in the U.K., prevention of the risk of relocation is effected by a special "exit charge" of 1.5% applied when shares are transferred to clearance services or converted into financial products that are excluded from the scope of the tax. 125 A drawback to the unilateral application of a worldwide FTT is potential enforcement and collection problems with regard to taxable transactions carried out abroad.