PREP Podcaster - ”Success Favours The PREPared Mind”

The Landmark FBAR Penalty Decision In Schwarzbaum: A Win for Taxpayers

September 9, 2024 - Participants include:

 

Virginia La Torre Jeker - @VLJeker

John Richardson - @Expatriationlaw

AI Description:

"Good morning. This is John Richardson speaking with you from Toronto, Canada. Today is Monday, September the 9th, 2024. And I'm starting my week off with a conversation with well-known U.S. Tax lawyer, Forbes columnist, and of course, her blog is even better, longtime repeat guest with me, Virginia LaTorre-Jeker. And today we are talking about a tremendously important both legal development and I think even more important sociological development in America.

Would you agree, Virginia?

Oh, I agree. It's quite important and has broad implications.

In this episode, we delve into the recent ruling by the 11th Circuit on the case of Mr. Schwarzbaum, a U.S. person penalized with significant FBAR penalties for failing to report foreign accounts. We discuss the implications of the court's decision, which could change the landscape for taxpayers facing similar penalties. The court ruled that FBAR penalties are subject to the Excessive Fines Clause of the Constitution, marking a significant win for taxpayers and potentially opening the door to challenging other penalties.

Join us as we explore the legal and sociological impact of this decision, the potential broader applications, and what it means for the future of penalty assessments in the U.S.

Anthony Parent Shares His Insights On: Navigating the Maze of PFICs And Other U.S. Tax Regulations for Expats

September 4, 2024 - Participants include:

John Alan Reese - @JohnAlanPod

Anthony Parent - @IRS_Medic

Keith Redmond - @Keith__Redmond

John Richardson - @ExpatriationLaw

On September 4, 2024 John Alan Reese interviewed Keith, Anthony and John (regular participants in the IRS Medic podcast).

I recommend the complete podcast which is available here:

https://www.youtube.com/watch?v=5AEpiebGj3k

In this clip Anthony Parent discusses (using the example of PFICs) the role that the tax preparation industry plays in interpreting the rules, creating the law and regulating the compliance of Americans abroad.

A shareable link to this clip is here:

https://www.listennotes.com/podcast-clips/proof-that-americans-who-live-abroad-are-Hx3XF-4fkPA/

 

AI description:

 

"In this episode, Anthony Parent, the face and voice of The IRS Medic, delves into the complexities of the U.S. tax system and its impact on expatriates. With a focus on the often misunderstood Passive Foreign Investment Companies (PFICs), Anthony sheds light on the misconceptions perpetuated by the tax industry and provides valuable insights into the history and purpose of PFIC regulations.

Listeners will gain an understanding of how the tax landscape has evolved, particularly since the 2009 Voluntary Disclosure Initiative, and the aggressive tax regimes that have emerged. Anthony shares his first-hand experiences and offers practical advice for those grappling with the intricacies of managing wealth both within and outside the U.S.

Tune in to discover how The IRS Medic can serve as a vital resource for anyone living in fear of the IRS and seeking clarity in the convoluted world of U.S. taxation."

The Difficult And Troubled Relationship That The "Democrats Abroad" Organization Has With Americans Abroad

September 4, 2024 - Participants include:

John Alan Reese - @JohnAlanPod

Anthony Parent - @IRS_Medic

Keith Redmond - @Keith__Redmond

John Richardson - @ExpatriationLaw

On September 4, 2024 John Alan Reese interviewed Keith, Anthony and John (regular participants in the IRS Medic podcast).

I recommend the complete podcast which is available here:

https://www.youtube.com/watch?v=5AEpiebGj3k

 

This podcast is an excerpt of Keith Redmond and John Alan Reese discussing the problem of finding support for Americans abroad. Both Keith and John note the difficult relationship that Democrats Abroad (and other organizations) have with Americans citizens abroad.

A direct (and shareable) link to this clip is here:

https://www.listennotes.com/podcast-clips/proof-that-americans-who-live-abroad-are-BmoQxHEu5I8/

 

 

 

 

 

 

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What US Citizenship Taxation Really Is - The Republicans Overseas Proposal To End It

September 4, 2024 - Participants include:

John Alan Reese - @JohnAlanPod

Anthony Parent - @IRS_Medic

Keith Redmond - @Keith__Redmond

John Richardson - @ExpatriationLaw

On September 4, 2024 John Alan Reese interviewed Keith, Anthony and John (regular participants in the IRS Medic podcast).

I recommend the complete podcast which is available here:

 

https://www.youtube.com/watch?v=5AEpiebGj3k

 

This podcast is an excerpt where I discuss the true nature of citizenship taxation. A possible supporter of citizenship taxation is somebody who is aware of citizenship taxation. An opponent of citizenship taxation is somebody who understand what it really is.

I also introduce the Republicans Overseas proposal to end citizenship taxation by severing citizenship from tax residency.

Here is a shareable link to this clip:

https://www.listennotes.com/podcast-clips/proof-that-americans-who-live-abroad-are-nmF0rLzkePb/

AI description:

 

"This episode delves into the fundamental problem of U.S. citizenship taxation, arguing that the issue is not merely the way Americans abroad are taxed, but the fact that they are subject to U.S. taxation at all. We explore the implications of the U.S. imposing its tax code on citizens who do not reside in the country and whose income is not sourced from the United States.

Our discussion highlights the emotional and financial toll this policy takes on expatriates, and how it effectively results in the U.S. "stealing" from other countries. We also examine the Republicans' overseas proposal, which aims to end the use of U.S. citizenship as a criterion for taxation, aligning U.S. policy with that of other nations."

The Dual Citizenship From Birth Exemption And Accidental Americans

September 4, 2024 - Participants include:

John Alan Reese - @JohnAlanPod

Anthony Parent - @IRS_Medic

Keith Redmond - @Keith__Redmond

John Richardson - @ExpatriationLaw

On September 4, 2024 John Alan Reese interviewed Keith, Anthony and John (regular participants in the IRS Medic podcast).

I recommend the complete podcast which is available here:

 

https://www.youtube.com/watch?v=5AEpiebGj3k

 

This podcast is an excerpt where I discuss the benefits that those born with dual citizenship - "citizenship non-taxation" - that are not available to others. The complete clip is available here:

https://www.listennotes.com/podcasts/the-comin-home/proof-that-americans-who-k8OC0dbmVa1/

 

AI - description:

 

"In this episode, John and the host - John Alan Reese - delve into the complexities faced by accidental Americans—individuals who hold U.S. citizenship unintentionally or are considering renouncing it. They explore how these unique circumstances affect their taxation and financial planning, both in the U.S. and abroad.

The conversation highlights the dual tax residency status of U.S. citizens, the challenges faced by those living outside the U.S., and the relief procedures available for former citizens. The episode provides valuable insights into the distinction between those born with dual citizenship and those who acquired it later in life, emphasizing the importance of understanding the U.S. tax system for financial survival."

Treasury Hearing August 21, 2024: Simplifying Foreign Trust Regulations: Voices from Abroad

Treasury Hearing On Foreign Trust and Foreign Gift Proposed Regulations - [REG-124850-08] - August 21, 2024

(My presentation starts at the 51 minute mark.)

 

The persons below have requested to present oral testimony on proposed regulations regarding “Transactions With Foreign Trusts and Information Reporting on Transactions With Foreign Trusts and Large Foreign Gifts” (REG-124850-08). A notice of proposed rulemaking and a notice of hearing were published in the Federal
Register on Wednesday, May 8, 2024.

 

Each speaker or group of speakers is allocated 10 minutes to speak.

In-Person Speakers

NAME REPRESENTING
1. Gary Carter Self - Start at approximate 61 minute mark
2. Henry P. Alden II - Start at approximate 10 minute mark
Karen Brodsky American Institute of CPAs (AICPA) - 14:10

3. Kevin Matz American College of Trust and Estate - Start at approximate 23:20 minute mark

Counsel (ACTEC)

Telephonic Speakers
4. Dennis Haszho Self - start at approximate 32:30 minute mark
5. Rebecca Lammers Democrats Abroad - Start at approximate 40:50 minute mark
6. John Richardson Stop Extraterritorial American Taxation - start at approximate 51 minute mark

Note that Gary Carter appeared by phone and started at the approximate 60 minute mark.

AI Description:

 

"In this episode, we dive into a pivotal IRS hearing concerning proposed regulations on foreign trusts and large foreign gifts, touching upon key sections of the Internal Revenue Code. Held at the IRS Auditorium in Washington, D.C., the hearing features a panel of experts and multiple speakers, including representatives from the American Institute of CPAs (AICPA), the American College of Trust and Estate Council (ACTEC), and various advocacy groups for Americans living abroad.

Our speakers share insights on the complexities and challenges faced by taxpayers, particularly those living outside the U.S., in navigating the intricate web of tax regulations. From the nuances of reporting non-U.S. pensions to the hefty penalties for non-compliance, the discussion underscores the urgent need for clarity and reform. Hear firsthand accounts from individuals and professionals alike, as they call for more lenient and clear-cut guidelines to better serve the global American community.

Join us as we explore the implications of these proposed regulations and the heartfelt testimonies advocating for a fairer and more straightforward tax system."

Navigating Departure Tax, Tax Residency and Leaving Canada

August 14, 2024 - Participants include:

 

Tim Smyth - @TPSmyth01

 

John Richardson- @ExpatriationLaw

 

Information about Canada's departure tax ...

 

AI description:

 

"Good morning, this is John Richardson speaking with you from Toronto, Canada. Today is Wednesday, August the 14th, and I am continuing my discussion with Tim Smyth in the Boston area about various aspects of tax residency and global mobility. In this episode, we delve into the intricacies of Canada's departure tax, especially when severing tax residency with Canada.

We explore the implications for Canadian residents with assets, including the rules around deemed sales of property and the exceptions to these rules. Tim shares his personal experience of leaving Canada before acquiring any assets and discusses the tax scenarios that would unfold if one were to move to Boston, severing tax residency with Canada.

We also touch upon the complexities of double taxation, the role of international treaties, and the specific assets that are excluded from Canada's departure tax. This episode offers valuable insights for anyone considering leaving Canada, highlighting the importance of understanding how different types of assets are taxed both in Canada and the destination country.

Tune in for a comprehensive discussion on tax residency, global mobility, and the financial considerations of moving across borders."

Birthday Reflections: Celebrating Coach Coutt's Journey

August 8, 2024 - Participants include:

 

Coach Coutts - @RealCoachCoutts

 

John Richardson -@ExpatriationLaw

 

AI Description:

 

 

 

 

Good afternoon, listeners! This is John Richardson speaking with you from Toronto, Canada. Today is Thursday, August 8th, 2024, and I have a special guest joining me for a birthday celebration podcast. It's Coach Coach's 39th birthday, and as tradition holds, we catch up on his extraordinary life in progress.

In this episode, Coach Coutts shares insights on maintaining a healthy lifestyle, the evolution of his training business, and the benefits of virtual training. We delve into his personal milestones, including his first year of marriage, navigating the Toronto housing market, and his commitment to continuous learning inspired by his mother.

Join us as we explore how Coach Coutts's enthusiasm for fitness and well-being remains unwavering, his proactive approach to marriage, and his future aspirations both personally and professionally. Plus, hear about his birthday traditions and plans, including a nostalgic trip to see the original "Terminator" movie in theaters.

Tune in for an engaging and inspirational discussion celebrating Coach Coutt's journey and the positive impact he's had on those around him."

Navigating Retirement Abroad: Understanding Tax Implications For "Retirees Abroad"

August 7, 2024 - Participants include:

 

Tim Symth - @TPSymth01

John Richardson - @ExpatriationLaw

 

 

AI Description:

"Join John Richardson from Toronto, Canada, as he continues his insightful discussion with Tim Symth from Boston. In this episode, they delve into the complexities faced by U.S. retirees living abroad and the potential impacts for "retirees abroad" of transitioning from a citizenship-based tax system to a residency-based taxation system.

John and Tim clarify the definition of a "retiree abroad" and explore the tax obligations these individuals face under the current U.S. citizenship-based taxation system. They discuss the fears and concerns associated with a shift to residency-based taxation, particularly drawing comparisons with the Canadian tax model.

The conversation highlights how U.S. retirees abroad, who primarily have U.S. source income, navigate their tax responsibilities and why they may not be motivated to support a change to residency-based taxation. Tune in for an in-depth analysis of the tax implications for U.S. citizens retiring overseas and the broader debate on taxation systems."

The Global Tax Tug-of-War: France's Citizenship Taxation Dilemma

July 31, 2024 - Participants include:

 

Tim Symth - @TPSymth01

John Richardson - @ExpatriationLaw

Laura Snyder: - @TAPInternation (providing the reason for the podcast)

 

Prologue:

A message rom Laura Snyder:

 

https://x.com/TAPInternation/status/1818299155275563265

 

AI description:

 

"In this episode, John Richardson from Toronto, Canada, reconnects with Tim Smyth from Boston to discuss the intriguing topic of citizenship-based taxation. As a long-time advocate for residency-based taxation for Americans abroad, Tim brings his insights on the recent political buzz in France about adopting citizenship-based taxation similar to the United States.

John and Tim delve into the historical context of tax treaties, the implications of France's extensive network of treaties, and why these treaties pose significant obstacles to France's proposed tax policy. They also explore the potential consequences for global tax sovereignty and the United States' unique position in the world of international taxation.

Tune in to understand the complexities behind France's ambitious tax proposal, the legal and constitutional challenges it faces, and the broader implications for global mobility and taxation."