Abstract

The worldwide rise of the Value-Added Tax over the last half-century is emblematic of the paradox in modern tax systems: their remarkable similarity in the face of divergent political, cultural and social systems. However, efforts to introduce VAT-style taxes have frequently been accompanied by fierce localized resistance. The histories of VAT reform in Australia, Canada and the United States encapsulate the tension that arises from a tendency among developed tax systems to converge against frequent and often fierce localized opposition. This tension speaks to a key debate in the public policy and comparative law literature concerning the transferability of policy ideas or legal instruments across jurisdictions. The Article details the history of VAT reform in Australia, Canada and the United States over a period of four decades, 1965-2005, where the global uptake of the VAT was at its highest, but where VAT reform in each jurisdiction was highly controversial. The Article concludes with an assessment of the factors that contribute towards tax policy convergence and localized resistance.