PREP Podcaster - “Success Favours The PREPared Mind”
Members of @SEATNOW_org: Understanding US @Citizenshiptax and why ending #FATCA will have no effect on US tax policies

Members of @SEATNOW_org: Understanding US @Citizenshiptax and why ending #FATCA will have no effect on US tax policies

January 20, 2021

January 20, 2021 - Participants Include:

 

John Richardson - @Expatriationlaw

Dr. Karen Alpert - @FixTheTaxTreaty

Dr. Laura Snyder - @TAPInternation

Suzanne Herman - @SuzanneHerman1

Keith Redmond - @Keith__Redmond

The core mission of SEAT is to "Stop Extraterritorial American Taxation". 

Extraterritorial American taxation is system that imposes worldwide taxation, on the non-US income of people who live outside the United States in other countries. US taxation of nonresidents is the reason for FATCA.

But:

1. Ending FATCA will NOT "Stop Extraterritorial American Taxation"; but

2. Ending "Extraterritorial American Taxation" will end the rationale for FATCA.

 

This podcast includes a discussion of (1) what Extraterritorial Americans taxation is and how it impacts people who live in other countries.

The message: individuals impacted by "Extraterritorial American Taxation" must understand that the "original sin" is "Extraterritorial American Taxation". Those impacted by these unjust and immoral U.S. tax policies must understand that this is a problem that is bigger than one individual. Things that do not affect you today could affect you tomorrow. Extraterritorial American Taxation must end.

 

"If we don't hang together, we will hang separately!"

 

Mobility Consultant David Lesperance: Canada as a destination of choice (some even think it’s a tax haven)

Mobility Consultant David Lesperance: Canada as a destination of choice (some even think it’s a tax haven)

January 17, 2021

January 3, 2021 - Participants include:

 

John Richardson

 

David Lesperance

 

Canada is a Westminster democracy. The Canadian constitution includes a "Peace, Order and Good Government Clause". It is a stable place to live, a stable place to invest and (probably) a stable place to retain your wealth.

It's no surprise that Canada continues to be a top choice for immigration.

My second podcast with David Lesperance discusses some of the additional reasons why many would be well advised to consider residence or a second residence in Canada.

 

 

 

Mobility Consultant David Lesperance: Why Second citizenship  and residence options are insurance in an unsettled  world

Mobility Consultant David Lesperance: Why Second citizenship and residence options are insurance in an unsettled world

January 11, 2021

January 3, 2021 - Participants Include:

John Richardson

David Lesperance

2020 was a difficult year for many and an unsettling year for all. It reinforced the dependencies people have on stability and predictability. It also reinforced the need for flexibility and "back up" plans.

In my first podcast of 2021 I discussed these issues  with mobility consultant David Lesperance of "Lesperance Associates".

David is the author of "Flight Of The Golden Geese" which explains the dependency that governments have on the tax revenues extracted from the few and why those few are incentivized to to seek alternative residences and citizenships. 

Retired UK Lawyer Describes How US Citizenship Taxation Impacts His Family AND The Sovereignty Of The UK And Other Countries

Retired UK Lawyer Describes How US Citizenship Taxation Impacts His Family AND The Sovereignty Of The UK And Other Countries

January 3, 2021

January 3, 2021 - Participants Include:

 

John Richardson - @ExpatriationLaw

Peter - A Retired London, UK Based Lawyer

This podcast features the experiences and perceptions of a person who is NOT and never was a U.S. citizen. But, approximately 40 years ago he married a U.S. citizen and had U.S. citizen children.

The discovery of U.S. citizenship tax rules led the family down a path of discovery where they gradually understood the principles of: U.S. citizenship, U.S. citizenship-based taxation and how the U.S. exports citizenship-based taxation to other countries.

The podcast includes a discussion of how the toxic mix of citizenship and U.S. taxation impacts individuals AND how it undermines the fiscal policies  of other nations (in this case the UK).

Of particular interest is a discussion of how the evolution of the law of U.S. citizenship (harder to lose) and U.S. taxation (infinitely more complex) has exacerbated the problem.

Ultimately, the problem is not FATCA. The problem is not citizenship. The problem is not even the rules of U.S. taxation.

The problem is that:

The United States is imposing worldwide taxation, on people who are tax residents of other countries and do NOT live in the United States.

This discussion is valuable for individuals with U.S. citizenship who are attempting to live productive and normal lives outside the United States.

The discussion is also valuable for those government policy makers who value the sovereignty of their countries and wish to end the U.S. creeping encroachment on the sovereignty of their countries. The discussion reminds me of a post that I write in 2015 describing how FATCA and U.S. tax rules burden Canada's sovereignty.

Ultimately all U.S. citizen members of the family renounced their U.S. citizenship.

Listening to this podcast explains why, for Americans abroad,  ...

"All Roads Lead To Renunciation!"

 

 

 

 

 

 

 

 

A California Plan To Chase Away The Rich, Then Keep On Stalking Them - Hank Adler

A California Plan To Chase Away The Rich, Then Keep On Stalking Them - Hank Adler

December 29, 2020

December 29, 2020 - Participants Include:

 

Hank Adler - Chapman University

John Richardson - @ExpatriationLaw

 

On December 18, 2020 Mr. Adler's article appeared on the Wall Street Journal began with:

"California’s Legislature is considering a wealth tax on residents, part-year residents, and any person who spends more than 60 days inside the state’s borders in a single year. Even those who move out of state would continue to be subject to the tax for a decade—a provision that calls to mind the Eagles’ famous “Hotel California” lyric: “You can check out any time you like, but you can never leave.”

 

You can read the complete article here ...

https://www.wsj.com/articles/a-california-plan-to-chase-away-the-rich-then-keep-stalking-them-11608331448?reflink=desktopwebshare_twitter

 

I am pleased to have interviewed Mr. Adler - a man with a wealth of experience in taxation and tax policy. If we sever the title of the Wall Street Journal article into two parts we see that:

1. On the one hand, California has a  - Plan To Chase Away The Rich - California tax policies are driving people away; and

2. On the the other hand California wants to  - Keep On Stalking Them -  California's proposed wealth tax purports to tax them on for ten years on their worldwide assets, which includes assets that have no connection to California and were acquired AFTER the individual moved from California.

This has many similarities to Exit taxes in general and the IRS Section 877A Expatriation Tax in particular.

By the way, those Canadians who winter in California and have sufficient assets would be subject to this proposed wealth tax!

 

 

 

Tax Haven USA: Why the USA is a great place to invest for nonresident aliens and how these investments might be structured

Tax Haven USA: Why the USA is a great place to invest for nonresident aliens and how these investments might be structured

December 15, 2020

November 12, 2020 - Participants include:

John Richardson - @Expatriationlaw

Jimmy Sexton - @JimmySextonLLM

 

"The United States has learned how to keep capital in and how to attract foreign capital!"

 

In this episode, Jimmy Sexton and John Richardson discuss why the United States is such an attractive place to invest for nonresident aliens. In other words, the opportunities are NOT available to U.S. citizens or U.S. residents.

Topics discussed include:

- how U.S. tax laws are desgined to attract foreign capital to from a U.S. tax perspective

- how U.S. tax laws which promote secrecy operate to enhance the role of the United States as a tax haven

- how the combination of FATCA (the U.S. demands your information but will not reciprocate) and the refusal to sign CRS (the U.S. will not share information) have enhanced the attractiveness of the United States as a tax haven

- how the use of LLCs and foreign Grantor Trusts can be used by nonresident aliens

- how the U.S. tax rules that are used to attract foreign capital planted the seeds that grew into  the current S. 877A expatriation tax

 Warning! Do NOT die with U.S. situs assets in your name. How to structure your assets to avoid the U.S. estate tax

 

There are Havens, Tax Havens and Tax Haven USA - there is no substitute!

 

 

 

Marc Zell - About The Association Of Accidental Americans. v. Department Of State

Marc Zell - About The Association Of Accidental Americans. v. Department Of State

December 10, 2020

December 10, 2020 - Participants Include:

 

John Richardson - @Expatriationlaw

 

Marc Zell - Jerusalem based International Lawyer

 

On December 9, 2020 the Association Of Accidental Americans launched a lawsuit against the US Department Of State on the basis that the $2350 USD renunciation is unconsitutional.

I am pleased to have been joined by their lawyer Marc Zell to discuss the lawsuit.

I have written a post discussing the claim here:

http://citizenshipsolutions.ca/2020/12/10/association-of-accidental-americans-v-us-department-of-state-is-the-2350-usd-renunciation-fee-constitutional/

A direct link to the claim is here:

 

http://citizenshipsolutions.ca/wp-content/uploads/2020/12/AAA-vs-DOS.pdf

 

 

 

 

Wealth Taxes Coming Soon To A Country Near You: Asset confiscation, income taxation or something else?

Wealth Taxes Coming Soon To A Country Near You: Asset confiscation, income taxation or something else?

December 4, 2020

November 12, 2020 - Participants Include:

 

John Richardson - @ExpatriationLaw

Jimmy Sexton - @JimmySextonLLM

It is becoming clear that the United States is gradually moving toward a tax system that includes taxation based on non-realization events. In other words, taxes may be owing even when there is no income.

Examples include (but are not limited to): the Subpart F regime (particularly the transition tax and GILTI) and the S. 877A Exit Tax Regime. The PFIC regime creates artificial income based on a fictional charge on tax deferral.

The recent Democratic Party nomination process introduced wealth taxes into the vocabulary of taxation. In particular, Elizabeth Warren campaigned on a platform of wealth taxation. In the case of a wealth tax there is no realization whatsoever. The tax is based ONLY on your owning an asset.

Although it is unlikely that a wealth tax will become a reality soon. But, it is coming. In fact, I think it would be appropriate to call the first version of the Wealth Tax: "The Senator Elizabeth Warren Wealth Tax".

On November 12, 2020 Jimmy Sexton and I discussed the nature of wealth taxes.

 

Locked Into US Citizenship: Do Americans Have The Right To Renounce? Should Renunciations Take Place Through Video Conferencing?

Locked Into US Citizenship: Do Americans Have The Right To Renounce? Should Renunciations Take Place Through Video Conferencing?

November 29, 2020

November 29, 2020 - Participants Include:

 

John Richardson - @Expatriationlaw

 

Diane Gelon - London, UK based New York lawyer

 

One the hand one, many Americans abroad are desparate to pay the $2350 USD fee to renounce US citizenship. On the other hand, the US State Department has stopped providing appoints to renounce.

Do US citizens have the right to renounce?

The 1868 Expatriation Act suggests that they have a statutory right to renounce.

Right of Expatriation

R.S. § 1999 provided that: “Whereas the right of expatriation is a natural and inherent right of all people, indispensable to the enjoyment of the rights of life, liberty, and the pursuit of happiness; and whereas in the recognition of this principle this Government has freely received emigrants from all nations, and invested them with the rights of citizenship; and whereas it is claimed that such American citizens, with their descendants, are subjects of foreign states, owing allegiance to the governments thereof; and whereas it is necessary to the maintenance of public peace that this claim of foreign allegiance should be promptly and finally disavowed: Therefore any declaration, instruction, opinion, order, or decision of any officer of the United States which denies, restricts, impairs, or questions the right of expatriation, is declared inconsistent with the fundamental principles of the Republic.”

The 1967 U.S. Supreme Court decision in Afroyim suggests they have a constitutional right to renounce.

The fact is that there is no bar to conducting renunication appointments through video conferencing. It's too bad that the US government won't allow this.

 

 

 

 

 

Valerie McCray 4: Discussion with @DrVMcCray2020 and her Financial Officer  Mary Lett - Is The US Tax Code Socialism For The Rich? How Do The Political Parties Maintain This?

Valerie McCray 4: Discussion with @DrVMcCray2020 and her Financial Officer Mary Lett - Is The US Tax Code Socialism For The Rich? How Do The Political Parties Maintain This?

November 21, 2020

November 21, 2020 - Participants include:

Dr. Valerie McCray - @DrVMcCray2020

John Richardson - @Independents

Mary Lett - Indianapolis based accountant and tax preparer

This is the fourth podcast with Dr. Valerie McCray. In this podcast we are joined by Mary Lett who is in charge of the finances for the Valerie McCray campaign. Our dicussion today focuses on the role that the US tax system has in keeping those who  are in need poor and maintaing the status of the upper middle class and wealthy.

 

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Interview 4: A fascinating discussion with Dr. Valerie McCray who is running as an independent candidate for President of the United States.  Please visit her site here.

The first interview with Dr. McCray is here.

The second interview with Dr. McCray is here.

The third interview with Dr. McCray is here.

 

Dr. Valerie McCray’s Story

Dr. Valerie McCray is a unique choice for President of the United States of America. She is entering the presidential race “straight from the trenches” as a psychologist that has spent most of her career working in the aftermath of tragedy.

Play this podcast on Podbean App