PREP Podcaster - ”Success Favours The PREPared Mind”

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

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."

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

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."

Unveiling Tax Reform: A Bright Future for Americans Abroad?

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."

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

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."

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

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."

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

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."

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

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."

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

 

 

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!"

The Fair Tax Revolution: A New Era in American Taxation

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."

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

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."