PREP Podcaster - ”Success Favours The PREPared Mind”

Beyond Borders: Rethinking Citizenship Taxation In A World Of Global Mobility

August 15, 2025 - AI Generated Podcast ...

This podcast is a discussion of a recent 2025 paper by Professors Ruth Mason of the University of Virginia and Tsilly Dagan of the University of Oxford title:

Reconsidering Citizenship Taxation

Both the paper and the AI generated podcast based on the paper are interesting. The paper discusses citizenship taxation as a theoretical concept. It in no way discusses the reality of citizenship taxation.

To put it simply:

A discussion of how citizenship taxation actually works and its effects on the lives of those inpacted by it is most notable in its absence.

 

AI description:

"This episode dives into how global mobility, remote work, and tax competition are disrupting traditional tax systems and the social contract. We unpack the rise of non-dom regimes, citizenship-for-sale, and digital nomads who challenge where income is sourced and taxed.

We explore the case for and against citizenship taxation—its promise to curb tax-motivated migration and its fairness claims—alongside alternatives like brain-drain taxes and exit taxes. Drawing on insights from Dagan and Mason, we probe what community membership really means and who owes what to whom.

Using the United States as a reality check, we examine the steep enforcement and compliance hurdles (think FATCA) that make citizenship taxation a "luxury policy" even for powerful states. We then consider whether cooperation could help—while noting the risks for global justice, individual liberty, and a deeper race to the bottom.

Finally, we spotlight a pragmatic path: combining citizenship and residence (and other indicators of belonging) to better align legal tax obligations with real community ties in a mobile world."

The Hidden Risks of Multiple Citizenship: Exploring The Challenges And Necessity Of Renunciation

August 8, 2025 - Speakers Include:

Alex Ugorji - @AlexUgorji

David Bindel - @DavidBindelTx

Mat Farel - @MatFarel

Parviz Malakouti - @ParvizMalakouti

John Richardson - @ExpatriationLaw

AI Description:

 

"Join Citizenship and Immigration Attorney Parviz Malakouti in a deep dive into the complexities surrounding citizenship renunciation. In this insightful episode, recorded on August 8th, Malakouti, alongside experts Alex Ugorji and John Richardson, explore the intricate web of laws and obligations that trap individuals in unwanted citizenships, highlighting the often-overlooked complications of extraterritorial obligations.

The discussion spans various geopolitical contexts, from the U.S. to Argentina, and delves into the unforeseen difficulties of acquiring and relinquishing multiple citizenships in today's interconnected world. Listen as experts debate the potential threats and strategic considerations for individuals seeking mobility and freedom in an era where citizenship laws are under increasing scrutiny.

Discover why more citizenships might not always offer more freedom, the looming threat of legal obligations that transcend borders, and why relinquishing citizenship can be a daunting task. Whether you're an aspiring global citizen or just curious about international law, this episode offers valuable insights into a rapidly evolving landscape."

Unraveling the Complexities of Tax Fraud and Denaturalization

August 5, 2025 - Participants include:

 

Virginia La Torre Jeker - @VLJeker

John Richardson - @ExpatriationLaw

 

Prologue:

On June 11, 2025, the Department of Justice issued a memo indicating that it planned to prioritize the denaturalization of certain U.S. citizens. In early August of 2025, media reports began circulating describing a naturalized citizen, who was subject to denaturalization proceeds, based on tax related conduct. Generally the media reports failed to distinguish between the innocent tax mistakes made by the many and the willful violation of tax laws engaged in by the few.

Podcast - AI generated description:

"In this enlightening episode, host John Richardson and special guest Virginia La Torre Jeker tackle the complex and often misunderstood topic of denaturalization due to tax-related issues. Broadcasting from Toronto, John discusses the legal intricacies with Virginia, who provides insights from her recent Forbes article - "Tax Fraud And Denaturalization Risks - A Balanced View For Taxpayers".

Through a detailed conversation, they differentiate between innocent tax mistakes and intentional tax fraud, highlighting the potential repercussions for naturalized U.S. citizens. Virginia emphasizes the importance of understanding these distinctions to prevent unnecessary panic amidst sensationalized media reports.

Tune in as the duo explores the statutory framework of the Immigration Nationality Act, specifically focusing on the provisions that can lead to the revocation of U.S. citizenship, and reflect on historical case law that informs current interpretations.

As tax professionals and legal advisors prepare to address public concerns, this episode aims to educate listeners, offering a calming and rational perspective on a challenging topic."

Congressman Hurd - H.R. 4501 - Exempt U.S. Citizen Pope Leo From U.S. taxation

July 30, 2025 - Speakers Include:

Dr. Laura Snyder - @TAPInternation

Parviz Malakouti - @ParvizMalakouti

BitCoin Backpacker - @BackPacker_BTC

John Richardson - @ExpatriationLaw

On July 17, 2025 Representative Hurd of Colorado introduced Bill H.R. 4501. The purposes of the bill would include the exemption of U.S. citizen Pope Leo from taxation under the Internal Revenue Code.

Congressman Hurd’s bill is discussed here:

https://citizenshipsolutions.ca/2025/07/29/colorado-congressman-jeff-hurd-recognizes-problems-of-u-s-citizenship-taxation/

This was an interesting and lively discussion which considered how Americans abroad might make use of H.R. 4501 in their mission to end U.S. citizenship taxation.

Dan Duggan and Roger Ver Extraditions: When Does A U.S. Citizen Lose Citizenship?

July 24, 2025

This is a recording of a discussion an “ X.com Space” hosted by U.S. immigration Parviz Malakouti. I (John Richardson) contributed to the discussion.

When exactly does a U.S. citizen relinquish U.S. citizenship?

 

X.com Handles:

Parviz Malakouti - @ParvizMalakouti

John Richardson - @ExpatriationLaw

Renunciation vs. Relinquishment Of U.S. Citizenship - Why The Difference Can Matter

July 21, 2025

This is a recording of a discussion an “ X.com Space” hosted by U.S. immigration Parviz Malakouti. I (John Richardson) contributed to the discussion.

X.com Handles

Parviz Malakouti - @ParvizMalakouti

John Richardson - @ExpatriationLaw

Unraveling the Hidden "Saving Clause" in Global Tax Treaties

This AI generated podcast is based on a paper written by Professor Leopoldo Parada. Although a “saving clause” has been a feature of U.S. tax treaties for years, the OECD Model Treaty did not have a “saving clause” before 2017. Interestingly, the OECD commentary suggests that the purpose of the “saving clause” was to allow for the taxation of controlled foreign corporations. The U.S. treaties exploit their version of he “saving clause” as a mechanism to employ U.S. citizenship taxation. The abstract of Dr. Parada’s paper includes:

“The 'OECD Saving Clause': An American-Tailored Provision Made to Measure the World

Rivista di Diritto Finanziario e Scienza delle Finanze, LXXVIII 1, I, 13-52 (2019)

41 Pages Posted: 18 Jul 2019

Leopoldo Parada

King's College London

Date Written: July 1, 2019

Abstract

This article argues that the “saving clause” provision introduced in the 2017 OECD Model conflicts with the entitlement to double taxation relief under Article 23 OECD Model, especially in cases involving the use of hybrid entities. Although this issue is pragmatically solved in the new paragraph 11.1 of the commentaries on Articles 23A and 23B OECD Model, which provides no obligation for the Contracting States to relieve double taxation to the extent that taxation is based exclusively on the residence of the taxpayer, it leaves the taxpayer in the residence state with a potential permanent double taxation status. The foregoing may be however avoided with an optional “reverse saving clause”. Such an option seems to be not only more coherent with the traditional object and purpose of tax treaties (double taxation relief), but it also reflects the tax treaty practice already in force in some countries around the world.”

AI generated commentary:

"In this episode, we delve into the intricacies of global tax agreements, focusing on a fascinating provision known as the 'saving clause.' Introduced in the 2017 OECD Model Tax Convention, this provision allows countries to maintain their right to tax their own residents, even in the presence of a tax treaty with another country. We explore the surprising conflicts it creates with the goal of double tax relief, especially in the context of hybrid entities.

Our discussion highlights the United States' historical use of the saving clause and its motivations rooted in unique taxation policies. We also contrast this with the 2017 OECD Model's approach and the issues it presents, particularly concerning hybrid entities that can lead to double taxation.

The episode offers insights into potential solutions, like the 'reverse saving clause,' which aims to mitigate double taxation and promote fairness. Join us as we navigate through these complex dynamics and consider the implications for global business and personal financial planning."

Unraveling the Green Card's Hidden Tax Obligations Triggered By Abandoning The Green Card

This AI generated podcast is from a John Richardson presentation about “Green Card Abandonment”. The presentation - “Understanding The Green Card (if you can)” - took place on May 1, 2024 on the IRS Medic Podcast.

AI Description:

 

"Think you know everything about a green card? Think again. In this episode, we explore the less-discussed side of holding a U.S. permanent residency: the lifelong tax obligations it entails. We uncover surprising insights with expert John Richardson, highlighting how a green card can bind you to U.S. tax requirements wherever you live. From understanding the divergence between immigration and tax statuses to navigating complex pre- and post-immigration planning, this episode acts as your guide through potential financial landmines.

Discover the implications of worldwide taxation for green card holders, the criticality of pre-immigration planning, and the reality of holding foreign assets and income while living in the U.S. Understand what being a 'treaty non-resident' means and the tools available to those living abroad or looking to sever ties with the U.S.

Hear about the criteria that determine 'long-term resident' status and the intricate processes involved in expatriation, including the looming threat of exit taxes and compliance with U.S. tax obligations. This episode provides a comprehensive guide to the myriad challenges that accompany a green card—far beyond just being a right to live in America."

How U.S. Citizens Abroad Are Subject To A More Punitive Tax System Than Are U.S. Residents

This AI generated podcast is based on an article written by John Richardson on March 12, 2019 at Citizenship Solutions. It was republished on March 13, 2019 post at Tax Connections. The Tax Connections version received a lot of comments. You can find the article on Tax Connections here. The comments are extremely interesting.

What follows is an AI generated description of the article.

 

"In this episode, we delve into the complexities of the U.S. taxation system imposed on its citizens living abroad. The discussion sheds light on how the U.S. tax code enforces a distinct, often more burdensome tax framework on American expatriates compared to their domestic counterparts. Through various examples and an insightful exploration, the episode reveals the challenges faced by these individuals, from punitive taxation on foreign income to the legal obstruction in utilizing foreign financial schemes meant for savings and retirement.

We explore the multifaceted issues arising from citizenship-based taxation, where Americans abroad not only pay their local taxes but also grapple with unique U.S. tax rules that arguably disadvantage them. The episode highlights the disparity in tax treatment based on residency and the implications it holds for fairness and equality within tax legislation. Additionally, we look at the complex compliance requirements that place excessive burdens on these citizens, often prompting controversial discussions around renouncing citizenship.

Join us as we examine the broader implications of these tax policies and their impact on global citizenship, raising questions about the intersection of identity, location, and global responsibilities in today's interconnected world."

A Simple Regulatory Fix For Citizenship Taxation

In November of 2020, SEAT members John Richardson, Karen Alpert and Laura Snyder published “A Simple Regulatory Fix For Citizenship Taxation”. This was the first article (and possibly suggestion) that the problems of Americans abroad could be solved through regulation.

We participated in a video podcast with Robert Goulder at Tax Notes.

Here is the AI Description of the article.

A Simple Regulatory Fix For Citizenship Taxation

1 source

This Tax Notes Federal article by John Richardson, Laura Snyder, and Karen Alpert examines the complex challenges faced by U.S. citizens living abroad due to America's citizenship-based taxation system. The authors argue that this system disproportionately burdens expatriates with duplicative and intricate tax compliance, often leading to double taxation and hindering their ability to engage in normal financial activities in their countries of residence. They propose that the U.S. Treasury has the regulatory authority and moral imperative to implement a "qualified nonresident" status, which would exempt these citizens from U.S. taxation on non-U.S. source income, thereby alleviating burdens on both expatriates and the IRS. Additionally, the article suggests several alternative regulatory changes to reduce specific compliance issues, such as those related to foreign bank accounts, retirement plans, mutual funds, and small business filings, highlighting that the IRS currently lacks the resources and expertise to effectively administer global tax enforcement.

 

What follows is the AI description of the podcast generated by Poedbean ...

 

"In this episode, we delve into the complex world of U.S. citizenship-based taxation and how it uniquely and often unfairly impacts Americans living abroad. Discover what it means to be caught between two tax systems and why the IRS is just as much a victim as the taxpayers themselves. We explore the persistent myths surrounding U.S. expats and the political challenges of enacting change. The episode highlights a potentially transformative regulatory solution that doesn't require congressional approval, aiming to ease the burden on both expatriates and the IRS. Tune in for a comprehensive discussion informed by a detailed study published in Tax Notes Federal, providing not only a sharp critique but also actionable solutions to a longstanding issue."