PREP Podcaster - ”Success Favours The PREPared Mind”

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."

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

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."

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

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."

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

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."

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

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?