PREP Podcaster - ”Success Favours The PREPared Mind”

When Borders Matter: How U.S. Estate & Gift Taxes Hit Global Families

AI version of pdf presentation:

John Richardson

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Warning!! This is a very complex area. I am not entirely happy with how AI generated this podcast. It's main. purpose is to highlight the importance of understanding your situation and getting proper advice!!

 

AI generated description:

 

This episode is a clear, practical deep dive into U.S. estate and gift taxes for people with international connections. We explain the three crucial taxpayer categories—U.S. citizens, U.S. domiciliaries who aren’t citizens, and non‑resident non‑citizens—how domicile is determined, and why U.S. situs assets (like U.S. real estate or U.S. stock) can trigger estate tax exposure.

We then explore how treaties can dramatically reshape outcomes—highlighting the U.S. treaties with Australia and Canada—plus common planning issues like transfers to non‑citizen spouses and QDOTs. The key takeaway: your citizenship, intent to reside, and where assets sit determine whether your legacy faces tiny or massive U.S. tax bills, so careful cross‑border planning is essential to avoid costly surprises.

Taxed From Afar: The Hidden Cost of U.S. Citizenship

September 6, 2025 - Participants include:

 

Latife Hayson - Youtube.com/@LatifeHayson

Dr. Karen Alpert - @FixTheTaxTreaty

Dr. Laura Snyder - @TAPInternation

John Richardson - @ExpatriationLaw

 

In July of 2025 Latife Hayson produced a lengthy video exploring the taxation of Americans abroad. 

 

Latife Hayson and a SEAT members Karen Alpert, Laura Snyder and John Richardson  discuss the real-life consequences of U.S. citizenship-based taxation for Americans living abroad, covering capital gains, exchange-rate effects, PFICs, reporting burdens and financial restrictions.

The conversation also explores practical advice for movers, the complexity of filing overseas, and prospects for policy change toward residency-based taxation.

Stay Strong to Be Strong: A 40-Year-Old’s Guide to Lasting Fitness

September 5, 2025 - Participants include:

David Coutts - @RealCoachCoutts

 

John Richardson - @ExpatriationLaw

 

AI generated description:

 

 

"John Richardson talks with Coach Coutts about turning 40, why strength matters for longevity, and how anyone—no matter their starting point—can begin improving fitness and mobility. They cover practical tips like walking, breathing, glute bridges, bird dogs, and prioritizing hip, shoulder-blade and core function to protect the spine and stay independent.

The episode emphasizes habits, mindset, and simple, affordable ways to get started (YouTube workouts, short routines, buddies or basic books), and includes Coach Coutts's contact info at coachcoutts.com for listeners who want personalized help."

When Birthright Becomes Burden: Living American, Abroad and Taxed

In February of 2015 I (John Richardson) did a presentation at a tax conference called:

 

"Sacred Trust: Counselling Clients Through The Trauma Of U.S. Citizenship Abroad in a "FATCAesque World"

 

I was curious to see what kind of podcast would be generated from the presentation. What follows is the result.

 

AI Generated:

 

"Imagine discovering that your U.S. citizenship — something you never actively chose — can create major financial, legal and emotional consequences while living abroad. This episode unpacks the shock of learning you are a U.S. person, the worldwide FATCA sweep that exposes you to banks and tax rules, and the life‑changing choices between remaining a citizen or expatriating.

We cover the mechanics of U.S. citizenship determination, the costly compliance and exit‑tax risks, and the deep personal trauma clients face. The episode emphasizes the role of advisors in guiding vulnerable clients through both legal strategy and the emotional decisions that shape their futures."

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