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Discussion about current events, culture, independent candidates, business, education, travel, death and taxes, global mobility, citizenship and residence by investment options, Americans abroad, FATCA, CRS, U.S. citizenship renunciation, Green Card abandonment, citizenship taxation, PFIC, GILTI, foreign trusts, I-407 and more ...
Episodes

Monday Apr 14, 2025
Monday Apr 14, 2025
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.
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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?

Saturday Apr 12, 2025
Saturday Apr 12, 2025
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.
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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:
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FBAR enforcement AKA The Obama/Biden “FBAR Fundraiser”
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the creation of the PFIC rules in 1986 (Reagan tax reform)
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Obama/Biden FATCA in 2010
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the Clinton Treasury Foreign Trust rules of 1996
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the Clinton Entity classification regulations of 1996
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the Obama OVDI/OVDP programs beginning in 2009
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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.
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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

Wednesday Mar 19, 2025
Breaking Down Barriers: Enabling US ETF Sales in the UK And A Call To Action
Wednesday Mar 19, 2025
Wednesday Mar 19, 2025
March 19, 2025 - Participants include:
Rebecca Lammers - @AbroadRebecca
John Richardson - @ExpatriationLaw
Context:
This podcast is suppleented by Rebecca's blog post here:
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."

Wednesday Mar 19, 2025
Decoding PFIC Form 8621: The IRS Response and Its Impact on Americans Abroad
Wednesday Mar 19, 2025
Wednesday Mar 19, 2025
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.
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."

Tuesday Mar 11, 2025
Unveiling Tax Reform: A Bright Future for Americans Abroad?
Tuesday Mar 11, 2025
Tuesday Mar 11, 2025
March 11, 2025 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @ExpatriationLaw
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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."

Monday Jan 27, 2025
Monday Jan 27, 2025
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."

Sunday Dec 22, 2024
Sunday Dec 22, 2024
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."

Saturday Dec 21, 2024
Groundbreaking Repeal: U.S. Senate Abolishes WEP for U.S. Citizens Living Abroad
Saturday Dec 21, 2024
Saturday Dec 21, 2024
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."

Friday Dec 20, 2024
A Breakthrough for Americans Abroad: Lahood's Tax Bill Explained
Friday Dec 20, 2024
Friday Dec 20, 2024
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."

Friday Dec 06, 2024
Bitcoin, Expatriation, Roger Ver and the Exit Tax: A Legal Showdown
Friday Dec 06, 2024
Friday Dec 06, 2024
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!"