PREP Podcaster - ”Success Favours The PREPared Mind” podcast

PREP Podcaster - ”Success Favours The PREPared Mind”

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Toward An Argument That US Citizenship Taxation Violates International Law 8:10

13 hours sitten8:10

8:10

May 4, 2025 - An AI conversion of a written blog post into a podcast ... Here is the original blog post from April of 2025: https://citizenshipsolutions.ca/2025/04/20/toward-an-argument-that-us-citizenship-taxation-violates-international-law/ AI - Generated podcast: This podcast episode delves into the complexities of FATCA litigation and U.S. citizenship taxation, exploring why legal challenges to FATCA often fail. The discussion emphasizes the distinction between addressing the symptoms of FATCA, such as privacy breaches and discrimination, and tackling its root cause: U.S. citizenship-based taxation. The episode scrutinizes the implications of the U.S. imposing tax obligations on citizens residing abroad, questioning whether this practice aligns with international law principles. It argues that U.S. citizenship taxation expands the U.S. tax base globally, often conflicting with the tax sovereignty of other nations and potentially violating customary international law (CIL). Listeners are encouraged to consider whether U.S. citizenship taxation, which bases tax residency on citizenship rather than physical or economic ties, is an outdated practice incompatible with modern international norms. The podcast aims to spark a broader discussion on the need for tax reform, particularly for Americans living overseas.…

PREP Podcaster - ”Success Favours The PREPared Mind”

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A U.S. Citizen as Pope? Exploring Tax Implications and Controversies 28:12

18 hours sitten28:12

28:12

May 4, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw Introduction: The idea for this podcast came from a New York Times article discussing the possibility of a U.S. citizen becoming the next Pope . It is likely that the Pope would have the authority - as per the FBAR Regulation : "to control the disposition of money, funds or other assets held in a financial account by direct communication (whether in writing or otherwise) to the person with whom the financial account is maintained." Could the U.S. Treasury impose FBAR penalties on a U.S. citizen Pope for failing to include the Vatican's accounts on an FBAR? The answer to this question was the topic of our discussion today. ______________________________________________ AI Description: In this intriguing episode, John Richardson from Toronto engages in a thought-provoking discussion with Virginia La Torre Jeker , a renowned U.S. tax lawyer based in Dubai, about the potential tax implications if a U.S. citizen were to become the Pope. The conversation delves into the complexity of U.S. tax laws, particularly FBAR (Foreign Bank Account Reporting), and how they could apply to a high-profile individual like the Pope, overseeing vast Vatican finances. The dialogue also explores the broader implications for U.S. citizens in positions of international power, the intersection of religious institutions and U.S. tax obligations, and the potential hurdles a U.S. citizen might face in such globally influential roles. Topical questions about financial transparency, the Vatican's compliance under FATCA, and the hypothetical responsibilities of the Pope regarding U.S. taxation and reporting rules are also addressed, shedding light on the challenges of citizenship, taxation, and global politics.…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Space 26 - April 14, 2025 - The Evolution of @CitizenshipTax - From 1979 - 2025 2:01:43

21 päivää sitten2:01:43

2:01:43

April 14, 2025 - Participants include: Dr. Suzanne de Treville - @SdeTreville Tim Smyth - @TpSmyth01 Brad - @InvertedFragility Brent Vanderbrook - @Vanderbrook Jacob - @Giorniofr John Richardson - @ExpatriationLaw Note: This podcast is a recording of an "X Spaces" discussion. The actual audio does not start until approximately the two minute mark. ____________________________________________ A truly fascinating discussion primarily by Brent Vanderbrook about the "ideology" of U.S. citizenship taxation. How does one engage in a discussion with people inside the USA (particularly US Treasury) about changing citizenship taxation?…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Space 25 - April 12, 2025: The 1980 Carter Report On Citizenship Taxation: Nothing Has Changed In 45 Years 2:40:22

23 päivää sitten2:40:22

2:40:22

April 12, 2025 - Participants include: Dr. Suzanne de Treville - @SdeTreville Tim Smyth - @TpSmyth01 Brad - @InvertedFragility Brent Vanderbrook - @Vanderbrook John Richardson - @ExpatriationLaw Note: This podcast is a recording of an "X Spaces" discussion. The actual audio does not start until approximately the two minute mark. _____________________________________ Introduction … In 1980 President Jimmy Carter filed a report on the topic of "U.S. Law Affecting Americans Living and Working Abroad". The Carter report was … “A legislative effort by Senator George McGovern required the President to conduct a thorough study of laws governing U.S. citizens abroad. This report by President Jimmy Carter was the first under that law - a painstaking review of the many legal provisions affecting U.S. citizens residing abroad. Issues include loss of citizenship by children born abroad, income tax, social security, veterans benefits and many other matters - and very little has changed since this report was written, so this is still a valuable legal guide for any American taking up foreign employment or residence.” The book is available here. It is a fascinating report in terms of its content. In addition, to the content it reveals the impressive work done by "American Citizens Abroad" in its formative years. Significantly, many of the problems that exist today were identified in 1980. Very little has changed for the better. Significantly the report is based on a world BEFORE: FBAR enforcement AKA The Obama/Biden “FBAR Fundraiser” the creation of the PFIC rules in 1986 (Reagan tax reform) Obama/Biden FATCA in 2010 the Clinton Treasury Foreign Trust rules of 1996 the Clinton Entity classification regulations of 1996 the Obama OVDI/OVDP programs beginning in 2009 Trump administration Transition Tax/GILTI rules of 2017 Note that EVERY ONE of these things is the result of U.S. citizenship taxation. The ONLY solution is a complete separation/severance of citizenship from tax residency. Hate to say it, but there is NO OTHER option. _______________________________________ On April 12, 2025 Dr. Suzanne de Treville led a discussion about the Carter report. Her discussion specifically referenced a presentation and spreadsheet which are at the following two links: https://docs.google.com/presentation/d/1_fN0iCzcBhftbiemFYEm9B7dQsCQp9O8bV7D0a70JV8/edit?usp=sharing https://docs.google.com/spreadsheets/d/1tCwz7RM2Uc1RV8o0rY7BBprVv3_357TSAJ-D4-eZicM/edit?usp=sharing In addition, Dr. de Treville referenced the earlier work of AARO, which is documented in the following post. https://citizenshipsolutions.ca/2024/01/21/the-unknown-ambassadors-a-saga-of-citizenship-phyllis-michaux/…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Breaking Down Barriers: Enabling US ETF Sales in the UK And A Call To Action 4:15

7 weeks sitten4:15

4:15

March 19, 2025 - Participants include: Rebecca Lammers - @AbroadRebecca John Richardson - @ExpatriationLaw Context: This podcast is suppleented by Rebecca's blog post here: https://medium.com/@tapinternational/dear-fca-please-change-the-regulations-so-us-citizens-in-the-uk-can-invest-in-us-etfs-61df27e40c76 AI Version: "Join John Richardson and Rebecca Lammers, the chair of the Democrats Abroad Taxation Task Force, as they discuss recent developments affecting U.S. citizens living in the U.K. In this special episode, Rebecca sheds light on the ongoing consultation by the U.K. Financial Conduct Authority and its implications for investment products like ETFs and mutual funds . The discussion emphasizes the difficulties faced by U.S. citizens in the U.K. in purchasing these financial products due to differing regulatory requirements. Rebecca highlights her personal submission for the U.K. government, striving for reforms that could ease these barriers and foster investment opportunities for U.S. expats. Tune in to explore how these potential changes may pave the way for a more accessible investment landscape."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Decoding PFIC Form 8621: The IRS Response and Its Impact on Americans Abroad 50:45

7 weeks sitten50:45

50:45

March 19, 2025 - Participants include: Rebecca Lammers - @AbroadRebecca John Richardson - @ExpatriationLaw Context: On March 1, 2025 the IRS released its response to public comments about PFIC Form 8621. The request for comments provided an opportunity for Americans abroad - a group disproportionately impacted by the PFIC problem - to report its disconent. The IRS response was surprising direct and "in effect" invited Americans abroad to engage in a "rulemaking process" to achieve the needed change. https://seatnow.org/2025/03/17/treasurys-response-to-form-8621-comments-the-good-the-bad-and-the-ugly/ Here is m discussion with Rebecca Lammers who heads the Democrats Abroad Taxation Task Force. AI Version "In this episode, John Richardson and Rebecca Lammers, head of the Democrats Abroad Taxation Task Force, discuss the recent IRS response to public comments on Form 8621 , known for its complexity and impact on Americans investing in foreign mutual funds. Rebecca shares her insights on the advocacy efforts to reform these tax rules and the steps being taken to hold the IRS accountable for their treatment of Americans abroad. The conversation also explores potential tax reforms for U.S. citizens living overseas and the ongoing legislative efforts to address these issues. The discussion highlights the challenges faced by Americans investing abroad, focusing on the PFIC form and the IRS's detailed acknowledgment of these challenges in their recent response. Rebecca also explains the importance of getting things on the record as part of advocacy to push for necessary reforms and the potential pathways to initiate a formal rulemaking process. Additionally, they touch upon the Residence-Based Taxation bill and the complexities surrounding its passage in Congress, offering insights into the legislative process and the need for continued support and awareness among the American expatriate community. Finally, they discuss the financial and volunteer support needed for continued advocacy and reform efforts, inviting listeners to contribute and get involved through Democrats Abroad and other organizations working towards fair taxation for Americans abroad."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Unveiling Tax Reform: A Bright Future for Americans Abroad? 26:37

8 weeks sitten26:37

26:37

March 11, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw ______________________________________ In this podcast we discuss Virginia's March 11, 2025 post: https://us-tax.org/2025/03/11/leaked-memo-includes-major-tax-reform-and-impacts-u-s-persons-abroad/ AI Description: "In this enlightening episode, host John Richardson discusses potential U.S. tax reforms with renowned tax lawyer Virginia La Torre Jeker. Together, they delve into a fresh memorandum suggesting significant changes that could impact Americans living abroad. Part A of Virginia's insightful blog post outlines proposals directly aimed at alleviating the tax burden on expatriates, while Part B explores unexpected benefits from proposed reductions in corporate tax rates. The conversation reveals contrasting approaches to tax reform, including debates around increasing the foreign earned income exclusion and the more radical idea of exempting all foreign income from U.S. taxes. The duo also examines inadvertent advantages these reforms could provide for expatriates, especially through lowering the U.S. corporate tax rate. Amidst discussions on the complexities of tax obligations for Americans overseas, Virginia sheds light on the intricate Controlled Foreign Corporation and GILTI tax regimes. Listeners are encouraged to explore these reforms' broader implications, as John and Virginia consider an optimistic outlook for future changes in tax policies."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Understanding the Complexities of Covered Expatriates And The U.S. 2801 Covered Gift Tax Provisions 41:39

14 weeks sitten41:39

41:39

January 25, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw Background: 1. Here is IRC S. 2810 2. Here are the 2801 Regulations effective January 1, 2025 AI Decription: "In this insightful episode, John Richardson hosts U.S. tax lawyer Virginia La Torre Jeker to unravel the complexities of U.S. tax exit provisions, focusing on the significant implications of the 2801 Transfer Tax. As they delve into the intricate regulations established by Congress through the 877A exit tax provisions and the 2801 covered gift tax provisions, John and Virginia provide an essential guide for expatriates and their families. The discussion highlights the burdensome regulations imposed by the U.S. tax code, especially for covered expatriates, and elaborates on what it means to be a covered expatriate. Virginia explains the various criteria and tests that determine one's status and discusses the significant penalties for non-compliance, including the harsh covered gift tax requirements. They also explore practical strategies for individuals facing these issues, detailing what it means to avoid or manage covered expatriate status. Furthermore, the episode examines the broader implications for U.S. citizens abroad and their families, urging them to stay informed and seek professional guidance to navigate these complex tax obligations effectively. The conversation serves as a crucial reminder of the importance of meticulous preparation when it comes to U.S. tax obligations and estate planning for those living outside the United States."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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The Year of 2024 in Review: "It Takes A Village" - Americans Abroad and Taxation Issues 40:41

19 weeks sitten40:41

40:41

December 22, 2024 - Participants include: Laura Snyder - @TAPInternation Keith Redmond - @Keith__Redmond John Richardson - @ExpatriationLaw AI Description: "Join hosts John Richardson, Keith Redman, and Laura Snyder as they delve into the intricacies of citizenship-based taxation and its impact on Americans living overseas. Broadcasting from Toronto, Washington D.C., and France, they discuss the year's significant events, from tax advocacy efforts to bills addressing double taxation and social security justice for Americans abroad. Listen in as they reflect on the challenges and successes of 2024, highlighting the struggle to decouple U.S. citizenship from tax residency and envision a fairer taxation system. With heartwarming holiday wishes, this episode offers insights and a rallying call for unity and change in the expat community's ongoing tax advocacy efforts."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Groundbreaking Repeal: U.S. Senate Abolishes WEP for U.S. Citizens Living Abroad 21:44

19 weeks sitten21:44

21:44

December 21, 2024 - Participants include: Doris Speer - @AARO President John Richardson - @ExpatriationLaw On December 21, 2024 the U.S. Senate passed H.R. 82 - The Social Security Fairness Act. H.R. 82 eliminated the "Windfall Elimination Provision" and the the "Government Pension Offset". Bottom Line: Many public employees in the United States and U.S. citizens living outside the United States will no longer have their Social Security pensions reduced. AI Description: "Hello from Toronto, Canada! On this momentous December 21st, 2024, John Richardson offers a deep dive into a significant shift impacting Americans living abroad. Forget about tax discussions; something monumental happened yesterday in the U.S. Senate. The Senate's approval of H.R. 82 marks the repeal of the Windfall Elimination Provision (WEP), a long-standing Social Security obstacle that unfairly reduced benefits for many Americans overseas. Host John welcomes Dora Speer, president of AARO in Paris, to demystify this issue and explore the milestone achieved through powerful advocacy. Tune in to understand why this repeal is essential for expatriates and how combined effort led to this landmark change. Plus, join the conversation on future tax reforms and how vital organizations like AARO are driving change for expats worldwide."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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A Breakthrough for Americans Abroad: Lahood's Tax Bill Explained 15:25

19 weeks sitten15:25

15:25

December 20, 2024 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw AI description: "In this insightful episode, John Richardson and U.S. Tax lawyer, Virginia La Torre Jeker, delve into the newly proposed Residence-Based Taxation for Americans Abroad Act introduced by Representative Darin Lahood. The bill aims to transition from the current citizenship-based taxation model to a more flexible elective residency-based system, offering potential relief for Americans living overseas." Virginia explains the elective nature of the new tax regime, highlighting who would benefit from opting in and the conditions required for eligibility. The discussion also examines its implications for high net worth individuals and the potential departure tax considerations. While the bill presents a promising shift, significant challenges and procedural uncertainties remain, particularly concerning IRS regulations yet to be defined. The conversation concludes with the recognition of the hurdles ahead and the anticipation of further discussions on the evolving landscape of U.S. taxation for expats."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Bitcoin, Expatriation, Roger Ver and the Exit Tax: A Legal Showdown 23:01

21 weeks sitten23:01

23:01

December 6, 2024 - Participants Include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw AI Description (with slight modifications): "Join John Richardson and Virginia La Torre Jeker as they dive into the riveting legal case involving Roger Ver, a pioneering figure in the world of Bitcoin, famously known as "Bitcoin Jesus." In this episode, they discuss the allegations of tax evasion and the U.S. Government's attempts to extradite him from Spain over charges stemming from the "exit tax." Virginia simplifies the complexities of the expatriation tax, illustrating why it may impact Bitcoin and other cryptocurrency investors. They further explore the significant legal ramifications of Ver's case, focusing on his efforts to comply with the expatriation regime and his legal team's challenge against the constitutionality of the exit tax itself. This discussion further delves into broader implications for Americans abroad, considering the potential constitutional challenges being posed against the unfair taxation without realization. Tune in for a captivating analysis that extends far beyond taxation law, inspecting its profound influence on expatriation rights and global mobility!"…

PREP Podcaster - ”Success Favours The PREPared Mind”

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The Fair Tax Revolution: A New Era in American Taxation 52:04

22 weeks sitten52:04

52:04

November 30, 2024 - Participants include: Jim Bennett- Fair Tax Steven Hayes Fair Tax John Richardson - @ExpatriationLaw I have previously hosted Jim Bennett and Steve Hayes of Fair Tax fame. Previous podcasts are available here . Much has happened since our last discussion. The November 5, 2024 election of Donald Trump coupled with Republican control of the Senate and House Of Representatives has created the opportunity for tax reform in the United States. As discussed in this podcast choices in taxation and really about choosing which form of taxation results in the least erosion of productive capital. There has never been a better time for substantive tax reforem in the United States. The prospects for the " Fair Tax " have never been better. Notably the Fair Tax would accomplish two goals: 1. It would turn the United States into a territorial tax system (the U.S. would NOT income/events outside the United States; and 2. It would replace the compliance costs and weaponization of the income tax with a simpler (and likely more fair) sales tax. Previous podcasts with JIm Bennett and Steve Hayes are available here: https://citizenshipsolutions.ca/category/fair-tax/ AI Description: "Join John Richardson from Toronto, Canada, as he discusses the exciting possibilities of tax reform in the wake of President Trump's election. With special guests Steve Hayes and Jim Bennett of Fair Tax fame, this podcast delves into the potential for implementing Fair Tax legislation in the United States. They explore how an open-minded administration could reshape taxation and return power to the American people. The conversation covers the implications of Fair Tax on investment, American expatriates, and the U.S. economy as a whole. Discover the impact of a consumption-based tax system and the opportunities it presents for both individuals and businesses. This is a must-listen for anyone interested in the future of American taxation and economic growth."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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The Continuing IRS Interest In Foreign Gifts And Expatriation: A New Question On Form 8854 For 2024 32:57

22 weeks sitten32:57

32:57

November 23, 2024 - Participants Include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw AI Description (with slight modifications): Part 1 - The Insanity Of "Foreign Gift Reporting" Continues "In this episode, join John Richardson and U.S. tax lawyer Virginia La Torre Jeker as they delve into the complexities of U.S. tax systems affecting "U.S. Persons" and the reporting of foreign gifts. They discuss an intriguing case where a woman from China was penalized for not reporting the receipt of foreign gifts, despite not being a "U.S. Person" when she received them, highlighting the extreme measures of the IRS." Part 2 - More Questions On Form 8854 For 2024 "The conversation also explores new developments in expatriation, touching upon changes in Form DS-4079 and the draft 2024 Form 8854, signaling increased IRS interest in expatriation processes. Specifically Form 8854 now asks whether gifts have been made withing a five year period which resulted in reducing a new worth below the 2 million USD mark. They shed light on the implications these changes have for expatriates, particularly focusing on the importance of understanding both U.S. and local laws regarding asset transfers and expatriation claims. Listen in to grasp the essential updates and avoid the risks involved in non-compliance with U.S. tax laws, especially when considering expatriation. This episode is vital for anyone dealing with expatriation or foreign assets concerning U.S. tax regulations."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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The Schwarzbaum "Adventures In FBAR Continue" - Government Seeks Clarification Of Willfulness 24:11

22 weeks sitten24:11

24:11

November 12, 2024 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw The Schwarzbaum chronicles continue ... AI description of podcast: "Join John Richardson from Toronto and U.S. tax lawyer Virginia La Torre Jeker as they delve into the new fascinating developments in the case of Mr. Schwarzbaum, a man who's making the intricacies of FBAR penalties understandable to everyone. This podcast episode explores the significance of the 11th Circuit's ruling that FBAR penalties are subject to the Eighth Amendment's Excessive Fines Clause, marking a monumental legal shift. Despite the ruling not significantly benefiting Mr. Schwarzbaum, it highlights the excessive nature of certain fines, offering a small victory for him but a huge win for many others. The U.S. Government has filed an appeal seeking to clarify the differences between "willfulness" in the civil FBAR penalty context and "willfulness" in the criminal penalty context. The U.S. Government appeal, seeking clarification on the definition of willfulness in both civil and criminal contexts, opens a broader discussion about the potential impacts on future legal interpretations and penalty enforcement. With engaging discussions on the complexities of FBAR penalties, the episode also touches upon the potential motivations of the U.S. Government in preserving its penalty base and the possible future developments in this high-stakes legal battleground. Whether you're an FBAR enthusiast or just a curious listener, this conversation is sure to shed light on the intricate world of taxes and penalties."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Exploring the New US DS-4079 Expatriation Form with Lawyer Diane Gelon 8:50

26 weeks sitten8:50

8:50

November 5, 2024 - Participants include: Diane Gelon - DianeGelon.com John Richardson - @ExpatriationLaw Effective November 1, 2024 the State Department introduced a revised DS-4079 which appears to standardize the renunciation process around the world. Initial information is here ... https://citizenshipsolutions.ca/2024/11/05/department-of-states-introduces-new-renunciation-form-and-processes-effective-november-1-2024/ Today I explore these changes with Diane Gelon. AI Description: "In this episode, we welcome back Diane Gelon, a seasoned expatriation lawyer from London, UK, to discuss the newly introduced US DS-4079 expatriation form. With over 35 years of experience in the field, Diane shares her insights on the implications and changes brought by this new form, which aims to streamline the process of renouncing U.S. citizenship globally. Diane and our host delve into the differences between the new form and its predecessor, highlighting its focus on intention and voluntariness in relinquishing citizenship. They explore the potential challenges and questions that may arise for individuals considering expatriation, including concerns about rights and privileges post-renunciation. Tune in for an engaging conversation that touches on the evolving landscape of expatriation law and what the future holds for those looking to navigate this complex process."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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The New Era of U.S. Expatriation: Navigating Changes in Form DS-4079 - Virginia La Torre Jeker 11:37

26 weeks sitten11:37

11:37

November 5, 2024 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw Effective November 1, 2024 the State Department introduced a revised DS-4079 which appears to standardize the renunciation process around the world. Initial information is here ... https://citizenshipsolutions.ca/2024/11/05/department-of-states-introduces-new-renunciation-form-and-processes-effective-november-1-2024/ Today I explore these changes with Virginia La Torre Jeker. AI Description: "Join John Richardson from Toronto and U.S. Lawyer Virginia LaTorre Jeker from Dubai as they delve into significant updates surrounding the expatriation process for U.S. citizens. On this pivotal day, November 5th, 2024, they discuss the newly revised DS-4079 form, now an 18-page document that consolidates various forms of relinquishment into a single, standardized procedure. The episode explores how these changes aim to bring consistency across U.S. consulates and embassies worldwide, reducing their autonomy in handling expatriation cases. The conversation highlights the increased emphasis on the intention behind relinquishment, suggesting a potential shift towards stricter scrutiny and possible refusals of renunciation. With expatriation numbers on the rise, this episode offers insights into the U.S. government's growing concern and its implications for citizens looking to renounce their citizenship. Tune in for an informative discussion on the future of expatriation and what it means for those seeking to navigate this complex process."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Is France Really Proposing Citizenship Taxation? A Discussion With @PatienceIsAlpha 38:33

26 weeks sitten38:33

38:33

November 3, 2024 - Participants include: Patience Is Alpha - @PatienceIsAlpha John Richardson - @ExpatriationLaw There has been occasional discussion about France (and other countries) beginning "citizenship taxation". Those who understand citizenship taxation will understand that it is used to keep people and capital locked in! For reasons previously discussed (tax treaties, etc.), it may be difficult for France to adopt citizenship taxation in a meaningful way. That said, over the last quarter century we have seen a reversal of the 20th century order. The first world democracies have used their tax systems to become some of the most repressive countries in the world. On the other hand, the least free countries of the 20th century are becoming less repressive. In today's podcast, I am joined by @PatienceIsAlpha (a prolific commentator on X.com). He has both a keen interest in tax residency, tax treaty and exit tax issues. He also has an interesting history. In this podcast he discusses his journey from France to becoming a Permanent Resident of Canada to becoming a Green Card holder in the USA. He is now confronted with the decision of whether to naturalize as a U.S. citizen. Will U.S. citizenship benefit him under the France U.S. tax treaty?…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Navigating Tax Challenges for Americans Abroad: A Conversation with Rebecca Lammers 1:03:50

26 weeks sitten1:03:50

1:03:50

November 1, 2024 - Participants include: Rebecca Lammers - @AbroadRebecca John Richardson - @Expatriationlaw AI Description: "Join John Richardson as he engages in a dynamic conversation with Rebecca Lammers, head of the Democrats Abroad Taxation Task Force, from her base in London. As an advocate for Americans abroad, Rebecca shares her journey from Ohio to becoming a pivotal voice in international tax reform discussions. Rebecca elaborates on the significance of November for American expatriates, the complexities of U.S. tax laws, and her role in the Taxpayer Advocacy Panel. Delve into the intricacies of tax compliance challenges faced by Americans living overseas and the advocacy efforts aimed at achieving residency-based taxation. Throughout the discussion, Rebecca highlights the strategic initiatives undertaken by Democrats Abroad, the hurdles of navigating a partisan Congress, and the importance of incremental reforms. With a focus on actionable steps and future goals, Rebecca emphasizes the need for continued advocacy and engagement to alleviate the tax burdens on Americans abroad. Tune in for insights into the ongoing efforts to reform U.S. tax policies and the collective push towards a more equitable system for expatriates worldwide."…

PREP Podcaster - ”Success Favours The PREPared Mind”

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IRS Eases Penalty Policy on Late Foreign Gift Reporting 11:21

27 weeks sitten11:21

11:21

October 25, 2024 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw This was a podcast that came together quickly. On October 24, 2024 the IRS announced that it would no longer automatically assess penalties to file Form 3520 reporting the receipt of foreign gifts. (The requirement is found in Internal Revenue Code 6039F (see below). Notably this does NOT end the penalty regime for the failure to report foreign gifts. It simply means that the penalties will no longer be assessed without considering reasonable cause. In the words of the Taxpayer Advocate: "Spoiler Alert The IRS has ended its practice of automatically assessing penalties at the time of filing for late-filed Forms 3520, Part IV, which deal with reporting foreign gifts and bequests. And… By the end of the year the IRS will begin reviewing any reasonable cause statements taxpayers attach to late-filed Forms 3520 and 3520-A for the trust portion of the form before assessing any Internal Revenue Code (IRC) § 6677 penalty. This favorable change will reduce unwarranted assessments and relieve burden on taxpayers by giving them the opportunity to explain their situation before the IRS assesses a penalty. TAS has recommended these changes for years and the IRS listened. IRS Commissioner Danny Werfel announced these changes during the UCLA Extension Tax Controversy Conference." The complete blog post is here ... https://www.taxpayeradvocate.irs.gov/news/nta-blog/irs-hears-concerns-from-tas-and-practitioners-makes-favorable-changes-to-foreign-gifts-and-inheritance-filing-penalties/2024/10/ ________________________________________ AI Description: "In this episode, John Richardson from Toronto, Canada, reconnects with Virginia Latorre Jeker to discuss a significant announcement by the IRS regarding foreign gift reporting. The IRS has revised its procedure and will no longer automatically impose penalties for late filing of Form 3520 when a U.S. person receives a foreign gift or bequest exceeding $100,000. This change comes after years of advocacy, including efforts by the National Taxpayer Advocate, highlighting the unfairness of the previous policy. Virginia explains that while the penalty regime remains in place, the IRS will now assess reasonable cause statements before issuing penalties, providing a fairer process for taxpayers. However, John and Virginia stress the importance of seeking professional advice to ensure compliance with reporting obligations and to craft strong reasonable cause statements if needed. They also clarify that this procedural change applies solely to foreign gift and bequest cases, not to other 3520-related issues. Virginia shares resources available on her tax blog for those interested in understanding more about foreign gift reporting requirements. The episode wraps up with a hint at future discussions on related topics." __________________________________________________________ Here is the text of Internal Revenue Code 6039F : 26 U.S. Code § 6039F - Notice of large gifts received from foreign persons (a)In general If the value of the aggregate foreign gifts received by a United States person (other than an organization described in section 501(c) and exempt from tax under section 501(a)) during any taxable year exceeds $10,000, such United States person shall furnish (at such time and in such manner as the Secretary shall prescribe) such information as the Secretary may prescribe regarding each foreign gift received during such year. (b)Foreign gift For purposes of this section, the term “ foreign gift ” means any amount received from a person other than a United States person which the recipient treats as a gift or bequest. Such term shall not include any qualified transfer (within the meaning of section 2503(e)(2) ) or any distribution properly disclosed in a return under section 6048(c). (c)Penalty for failure to file information (1)In generalIf a United States person fails to furnish the information required by subsection (a) with respect to any foreign gift within the time prescribed therefor (including extensions)— (A) the tax consequences of the receipt of such gift shall be determined by the Secretary, and (B) such United States person shall pay (upon notice and demand by the Secretary and in the same manner as tax) an amount equal to 5 percent of the amount of such foreign gift for each month for which the failure continues (not to exceed 25 percent of such amount in the aggregate). (2)Reasonable cause exception Paragraph (1) shall not apply to any failure to report a foreign gift if the United States person shows that the failure is due to reasonable cause and not due to willful neglect. (d)Cost-of-living adjustment In the case of any taxable year beginning after December 31, 1996, the $10,000 amount under subsection (a) shall be increased by an amount equal to the product of such amount and the cost-of-living adjustment for such taxable year under section 1(f)(3), except that subparagraph (A)(ii) thereof shall be applied by substituting “1995” for “2016”. (e)Regulations The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this section. (Added Pub. L. 104–188, title I, § 1905(a) , Aug. 20, 1996, 110 Stat. 1913 ; amended Pub. L. 115–97, title I, § 11002(d)(13) , Dec. 22, 2017, 131 Stat. 2062 .)…

PREP Podcaster - ”Success Favours The PREPared Mind”

1
Navigating the Complexities of U.S. Green Card Holders: Risks and Responsibilities (and entering the USA) 22:44

28 weeks sitten22:44

22:44

October 18, 2024 - Participants include: Virginia La Torre Jeker- @VLJeker John Richardson - @ExpatriationLaw On October 16, 2004 Virginia published the following article in Forbes: Surrender Green Card At The Border: Form I-407, U.S. Tax Expatriation Today we discuss that article. AI Description: "Join host J ohn Richardson from Toronto as he engages in an insightful conversation with Virginia La Torre Jeker, a renowned U.S. lawyer based in Dubai. This episode delves into the multifaceted world of U.S. green card holders, exploring the significant life decisions and potential tax implications associated with holding and relinquishing a green card. Virginia, a Forbes contributor and experienced blogge r, shares her expertise on the delicate balance of maintaining U.S. residency and the legal and tax considerations for green card holders. Discover why obtaining a green card is a monumental decision, comparable to acquiring a new status in life, and learn about the critical procedural steps necessary for those looking to sever their U.S. tax residency." Gain valuable insights into the complexities of long-term residency, expatriation, and the potential pitfalls that green card holders may encounter at U.S. borders. Whether you're a current green card holder or considering applying for one, this episode provides essential knowledge to help you navigate the intricate landscape of U.S. immigration and tax laws."…

PREP Podcaster - ”Success Favours The PREPared Mind”

1
Navigating Second Citizenship and U.S. Taxation: A Conversation with @TheJerzWay 51:58

28 weeks sitten51:58

51:58

October 14, 2024 - Participants include: Jerz - @TheJerzWay John Richardson - @ExpatriationLaw President Trump's announcement to end double taxation for Americans abroad has received great attention. It's clear what it means for long term U.S. emigrants. Another groups of Americans abroad includes digital nomads and remote workers. A long time commentator on digital nomads is Jerz (a U.S. citizen abroad). He recently supported support for President Trump's initiative suggesting that it was a reason why all Americans abroad should vote for Donald Trump. https://x.com/TheJerzWay/status/1845155499890683978 I thank Jerz for joining me in this podcast which took place on October 14, 2024. _________________________________________ AI Description: "Join John Richardson in a compelling discussion with Jerz, a prominent figure in the Second Citizenship, Digital Nomad, and Global Mobility space, as they explore the intricacies of acquiring second citizenships and the challenges posed by U.S. citizenship-based taxation . Broadcasting from Toronto, Canada, on Thanksgiving Day, John welcomes Jerz, who is speaking from Brazil, to delve into this transformative journey. In this episode, Jerz shares his insights on the three primary paths to obtaining a second citizenship: by descent, investment, and residency. He provides a detailed overview of each method, highlighting the benefits and potential pitfalls. The conversation shifts to the broader implications of U.S. citizenship-based taxation , discussing President Trump's proposal to end this practice and how it affects Americans living abroad. Jerz emphasizes the importance of understanding the financial and personal impact of U.S. taxation laws, urging listeners to consider the value and purpose of acquiring another citizenship. Whether you're an American abroad or contemplating a move, this episode offers valuable perspectives on navigating global mobility and the potential benefits of policy change."…

PREP Podcaster - ”Success Favours The PREPared Mind”

1
Taxation Without Borders: The Republicans Overseas Proposal To End Citizenship-Based Taxation 44:58

29 weeks sitten44:58

44:58

July 10, 2024 - Participants include: Vance - @MyLatinLife John Richardson - @ExpatriationLaw In this episode we discuss the 2024 Republicans Overseas Tax proposal to end U.S. citizenship taxation . AI Description: "Welcome back to the My Latin Life podcast ! Since 2014, we've been your trusted guide to traveling and living in Latin America. In this episode, we reconnect with John Richardson , an expert in expatriation law, to discuss the complexities of American taxation abroad. John is part of SEAT (Stop Extraterritorial American Taxation) , an organization advocating for significant changes to the taxation laws affecting Americans living overseas. Join us as John delves into the latest developments in the fight against citizenship-based taxation . He shares insights on the role of Republicans Overseas in advancing this cause and discusses the potential for legislative and regulatory changes. We explore the complexities of U.S. tax jurisdiction and the impact on Americans who live and work abroad, highlighting the need for reform to align with global standards. Whether you're a digital nomad or an American expatriate, this episode provides valuable information on how you can get involved in advocating for change. Tune in to learn more about the efforts to sever the link between citizenship and tax residency and the potential implications for the future."…

PREP Podcaster - ”Success Favours The PREPared Mind”

1
Trump’s Proposal To End Double Taxation Of Americans Abroad Discussed By Tax Academics 21:18

29 weeks sitten21:18

21:18

October 11, 2024 - Participants include: Dr. Karen Alpert - @FixTheTaxTreaty Dr. Laura Snyder - @TAPInternation John Richardson - @Expatriationlaw About SEAT: The purpose of SEAT has been and continues to be to conduct research (including the SEAT survey ), prepare position papers, make submissions by SEAT to various governments, facilitate advocacy by individuals impacted, file amicus briefs and provide a centre for educating interested parties about the U.S. extra-territorial tax regime. (SEAT's work may be found on the SEAT website .) SEAT believes that the problems caused to Americans abroad by the U.S. extraterritorial tax regime can be ended ONLY by severing citizenship from tax residency . We encourage the United States to join the rest of the world by taxing individuals on the basis of residence and source and NOT based on the citizenship of an individual. This particular podcast is a response to a Tax Notes article discussing the recent Trump proposal to end the double taxation of Americans abroad. The article is found here: https://www.taxnotes.com/tax-notes-today-federal/financial-reporting/trump-vows-end-double-taxation-overseas-citizens/2024/10/11/7m68f Of particular interest, and the reason for this podcast, is the following excerpt quoting Professor Avi-Yonah : "Reuven S. Avi-Yonah of the University of Michigan Law School believes concerns over double taxation are exaggerated, noting that in addition to the income exclusion limit and tax credit, many U.S. citizens live in countries that have a tax treaty with the United States, and those treaties often provide “tiebreakers” to ensure there isn’t double income taxation. “Thus, the double taxation argument is spurious,” Avi-Yonah said in an email. “There are many more cases where Americans living overseas enjoy double non-taxation because of sections 911 or 933 than cases of double taxation.” We disagree both the general sentiment expressed and the claim that the treaty tie-break provision is available to U.S. citizens living outside the United States. AI Description: "In this episode, John Richardson from Toronto, Canada, discusses a major proposed development in U.S. taxation policy with Dr. Laura Snyder in Paris and Dr. Karen Alpert in Australia. President Trump's recent announcement to end the double taxation of American citizens abroad has stirred significant interest and controversy. The discussion centers around an article from Tax Notes and the differing perspectives described in the article about this policy shift. Dr. Snyder and Dr. Alpert, both members of the organization " Seat Stop Extraterritorial American Taxation Now ," delve into the complexities and implications of the U.S. tax system for Americans living overseas. They critique the views of Professor Ruven Avi-Yonah, who argues that concerns over double taxation are exaggerated and often mitigated by the "treaty tie break" provision tax treaties. The conversation highlights the challenges faced by expatriates, including definitional and timing issues in tax codes, which can lead to double taxation despite the existence of tax treaties. The episode calls for more inclusive dialogue involving experts with firsthand experience of these tax challenges, advocating for a reevaluation of the U.S. citizenship-based taxation system."…

PREP Podcaster - ”Success Favours The PREPared Mind”

1
Ending Double Taxation of Americans Abroad: A Conversation with Solomon Yu on the Future of Citizenship Taxation for Americans Abroad 45:51

30 weeks sitten45:51

45:51

October 4, 2024 - Participants Include: Solomon Yue - @SolomonYue John Richardson - @ExpatriationLaw Introduction: Republicans Overseas recently announced that President Trump has recognized the unfairness of the tax treatment of Americans abroad and has committed to the principle of eliminating double taxation on them. In this podcast I discuss this message and explore what it means for Americans abroad. AI description: " In this engaging episode, host John Richardson reconnects with Solomon Yu, a long-time advocate for ending the double taxation of Americans living overseas. From Toronto to Oregon, the conversation spans continents and decades of activism, as Solomon shares his personal journey from escaping communist China to becoming a key figure in Republican politics and a founder of Republicans Overseas. Solomon discusses the challenges and triumphs in his decade-long fight against citizenship-based taxation, highlighting the latest breakthrough: a recognition from former President Donald Trump on the need to address this issue. The episode delves into the complexities of U.S. tax laws affecting Americans abroad, the historical context of this advocacy, and the potential impact of Trump's support in the upcoming elections. Listeners are taken through a narrative of perseverance, legal battles, and political strategy, as Solomon outlines the path forward for Americans overseas. With insights into the political mechanisms at play and a call to action for voting, this episode is a must-listen for anyone interested in the intersection of tax policy, expatriate rights, and American politics."…

PREP Podcaster - ”Success Favours The PREPared Mind”

1
The Tax Trap: Navigating U.S. Taxation for Americans Abroad 46:34

31 weeks sitten46:34

46:34

September 4, 2024 - Participants include: John Alan - @JohnAlanPod Keith Redmond - @Keith__REDMOND Anthony Parent - @IRS_Medic John Richardson - @ExpatriationLaw Note: This podcast was hosted by John Alan and originally was published by him on September 8, 2024 at his John Alan Pod site . The podcast is reposted here with the kind permission of John Alan. AI Description: "Join host John Allen in this episode of " Coming Home with John Allen " as he discusses the complex world of U.S. taxation for Americans living overseas with tax experts John Richardson , Anthony Parent , and Keith Redman . These seasoned professionals dive deep into the intricacies of the U.S. tax code, particularly how it impacts American expats and emigrants. Discover the distinctions between short-term expats and long-term emigrants, and how the U.S. tax system treats them. The conversation highlights the severe challenges faced by Americans abroad, including the citizenship-based taxation system, the threat of double taxation, and the lack of proper representation and protection. Learn about the proposed solutions, such as severing U.S. citizenship from tax residency and reforming the current tax regulations. Gain insights from personal experiences and expert advice on how to navigate the tax landscape, mitigate fear , and make informed decisions. This episode is a must-listen for anyone grappling with the complexities of U.S. taxes while living overseas."…

PREP Podcaster - ”Success Favours The PREPared Mind”

1
The Landmark FBAR Penalty Decision In Schwarzbaum: A Win for Taxpayers 23:27

34 weeks sitten23:27

23:27

September 9, 2024 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @Expatriationlaw AI Description: "Good morning. This is John Richardson speaking with you from Toronto, Canada. Today is Monday, September the 9th, 2024. And I'm starting my week off with a conversation with well-known U.S. Tax lawyer, Forbes columnist , and of course, her blog is even better, longtime repeat guest with me, Virginia LaTorre-Jeker. And today we are talking about a tremendously important both legal development and I think even more important sociological development in America. Would you agree, Virginia? Oh, I agree. It's quite important and has broad implications. In this episode, we delve into the recent ruling by the 11th Circuit on the case of Mr. Schwarzbaum, a U.S. person penalized with significant FBAR penalties for failing to report foreign accounts. We discuss the implications of the court's decision, which could change the landscape for taxpayers facing similar penalties. The court ruled that FBAR penalties are subject to the Excessive Fines Clause of the Constitution, marking a significant win for taxpayers and potentially opening the door to challenging other penalties. Join us as we explore the legal and sociological impact of this decision, the potential broader applications, and what it means for the future of penalty assessments in the U.S.…

PREP Podcaster - ”Success Favours The PREPared Mind”

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Anthony Parent Shares His Insights On: Navigating the Maze of PFICs And Other U.S. Tax Regulations for Expats 2:50

34 weeks sitten2:50

2:50

September 4, 2024 - Participants include: John Alan Reese - @JohnAlanPod Anthony Parent - @IRS_Medic Keith Redmond - @Keith__Redmond John Richardson - @ExpatriationLaw On September 4, 2024 John Alan Reese interviewed Keith, Anthony and John (regular participants in the IRS Medic podcast ). I recommend the complete podcast which is available here: https://www.youtube.com/watch?v=5AEpiebGj3k In this clip Anthony Parent discusses (using the example of PFICs) the role that the tax preparation industry plays in interpreting the rules, creating the law and regulating the compliance of Americans abroad. A shareable link to this clip is here: https://www.listennotes.com/podcast-clips/proof-that-americans-who-live-abroad-are-Hx3XF-4fkPA/ AI description: "In this episode, Anthony Parent, the face and voice of The IRS Medic , delves into the complexities of the U.S. tax system and its impact on expatriates. With a focus on the often misunderstood Passive Foreign Investment Companies (PFICs), Anthony sheds light on the misconceptions perpetuated by the tax industry and provides valuable insights into the history and purpose of PFIC regulations. Listeners will gain an understanding of how the tax landscape has evolved, particularly since the 2009 Voluntary Disclosure Initiative, and the aggressive tax regimes that have emerged. Anthony shares his first-hand experiences and offers practical advice for those grappling with the intricacies of managing wealth both within and outside the U.S. Tune in to discover how The IRS Medic can serve as a vital resource for anyone living in fear of the IRS and seeking clarity in the convoluted world of U.S. taxation."…

PREP Podcaster - ”Success Favours The PREPared Mind”

48 weeks sitten1:48

1:48

June 1, 2024 John Richardson - @Expatriationlaw This podcast introduces a the oral argument in the U.S. Supreme Course in the seminal case of Afroyim v. Rusk. Afroyim has been referenced and discussed from time to time in the 16 part podcast discussing Laura Snyder's "Working Paper Series" (found on the SEAT website here ). The case was about whether Mr. Afroyim could be stripped of his U.S. citizenship for voting in an Israeli election when he was a resident but not a citizen of Israel. Interestingly, during the oral argument, the U.S. government lawyer - Charles Gordon - tried to expand the issue into whether Mr. Afroyim should have been stripped of his U.S. citizenship by later accepting Israeli nationality under Israel's "right of return" law. Fortunately, the Court did NOT allow the government to do this. Mr. Gordon was a major figure in U.S. immigration law. His 1999 death rated an article in the New York times . Interestingly the article included a reference to his involvement in the Afroyim case.as follows: "He spent several years in private practice before joining the Immigration and Naturalization Service in 1939. He stayed for 35 years, rising to general counsel in 1966. While at the immigration agency, Mr. Gordon argued eight cases before the Supreme Court. ''He was known as a liberal and someone in favor of a more open, fairer immigration policy,'' Mr. Roberts said, but sometimes he had to argue positions with which he disagreed. In one such instance, three decades ago, Mr. Gordon lost the case of Afroyim v. Rusk, in which the Supreme Court ruled that a naturalized citizen cannot lose his citizenship against his will by voting in a foreign election." Please see the following AI generated description and listen to the argument as it took place in 1967 in the Supreme Court of the United States here: https://www.oyez.org/cases/1966/456 AI Description: "Good evening, this is John Richardson speaking with you from Toronto, Canada. Today is June 1st, 2024. All Americans abroad will understand or should understand the significance of the 1967 U.S. Supreme Court decision in Afroyim v. Rusk. That's Afroyim v. Rusk. Essentially, the case held that the U.S. Government could not involuntarily strip U.S. Citizens of their U.S. citizenship, a practice that continued right up until the 1986 amendments to the Immigration and Nationality Act. Afroyim was the seminal case, and it was decided in 1967. The facts revolved around Mr. Afroyim's voting in an Israeli election in 1951, despite not being a citizen of Israel. Interestingly, today I discovered a website - Oyez.org - that replicates the exact arguments made before the Supreme Court of the United States in various decisions, including Afroyim v. Rusk. I just finished listening to it, and it is absolutely fascinating. I thought you might be interested in listening to this as well. Please click on the link in the description and enjoy yourself. It's about an hour and ten minutes and highly, highly informative. Thanks for listening." Once again, the link is here: https://www.oyez.org/cases/1966/456…

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