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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
Friday Mar 24, 2023
Friday Mar 24, 2023
Friday March 24, 2023 - Participants include:
Jeff Steiner - @JeffSteiner
John Richardson - @Expatriationlaw
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Democrats abroad has members who are entitled to vote within the party and have the potential to impact party policy.
Democrats Abroad France has an election - voting is April 1, 2023 - which will determine who some of those voting members are. Jeff Steiner is a candidate. You can vote for him on April 1, 2023.
In this podcast I meet Jeff and discuss some of the reasons why he believes that Residence-based taxation and FATCA repeal are a priority for Americans abroad.
You can learn more about Jeff at:
Tuesday Mar 21, 2023
Tuesday Mar 21, 2023
March 21, 2023 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
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The United States is determined to get its tax revenue. The U.S. Internal Revenue Code has provisions that:
Prohibit People From Leaving The Country For Tax Related Reasons
Examples include:
- Passport confiscation laws for citizens
- A requirement of a tax certificate for non-citizens ("Sailing Permit")
Take Control Over People's Money If They Are Neither Citizens Nor Residents
Examples include:
- withholding taxes generally
- FIRPTA
- Estate taxes on US Situs assets ($60,000 USD threshold).
Make it difficult for U.S. citizens to access their money in the United States if they are living outside the United States
Example includes:
- various filing requirements that apply to Americans abroad that do NOT apply to resident Americans
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In today's podcast Virginia La Torre Jeker and John Richardson discuss the "sailing permit" AKA the mechanism designed to prohibit non-citizens from leaving the United States. Read more here:
Friday Mar 17, 2023
Friday Mar 17, 2023
March 17, 2023 - Participants include:
Anthony Parent - @IRS_Medic
Keith Redmond - @Keith__Redmond
John Richardson - @Expatriationlaw
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For those renouncing U.S. citizenship a perceived "loss of identity" is a factor.
But, those renouncing U.S. citizenship need NOT lose their identity as Americans.
They simply become:
"Retired American Citizens" - They remain Americans but they lose all the obligations!!
Those who cannot imagine themselves as retired should listen to the Dodge Stratus podcast:
"You aren't losing a sports car! You are gaining two doors!!"
For those who renounce:
"You are not losing your identity as an American. You are simply gaining your freedom from the regulatory regime!!"
For those who missed the Dodge Stratus podcast:
Thursday Mar 16, 2023
Thursday Mar 16, 2023
March 16, 2023 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
On March 16, 2023 Virginia La Torre Jeker published a post titled:
The Perfect Storm - U.S. Tax, Community Property and The Mobile International Couple
"Once upon a time:
Two UK nationals who were married were exiled from Uganda, moved to Belgium (a community property jurisdiction). The husband had substantial U.S. stock registered in his name. He died and an estate tax was owed to the IRS."
This case combines elements of:
- how the U.S. estate tax applies to U.S. situs assets owned by individuals who are neither U.S. citizens nor domiciled in the U.S.
- the difference between ownership of assets in a community property jurisdiction (Belgium) and a separate property jurisdiction (U.K.)
- how "conflict of law rules" will determine which jurisdiction's law applies to determine property ownership.
The couple did NOT "Live Happily Ever After!
Tuesday Mar 14, 2023
Tuesday Mar 14, 2023
Congressman Higgins Asks United States Trade Representative to Request Consultations Related to Canada’s Underused Housing Tax
Congressman Brian Higgins (NY-26) is asking United States Trade Representative Katherine Tai to open formal consultations with the Government of Canada to explore if the Underused Housing Tax is inconsistent with the United States-Mexico-Canada Agreement (USMCA).
In a letter to Ambassador Tai, Rep. Higgins writes, “The United States and Canada have a longstanding, cooperative, and mutually beneficial relationship. Western New York and Southern Ontario exemplify this unique bond. The UHT’s impact on Americans who own property in Canada, however, threatens our binational community and appears to be inconsistent with the USMCA.”
One of the principles of the USMCA is the requirement that all parties not discriminate against each other or provide preferential treatment solely to domestic companies or citizens, including with respect to internal taxation. Canada’s Underused Housing Tax does not apply equally to Canadian and U.S. citizens and therefore may violate these principles. The USMCA stipulates parties can request consultations with another party when trade agreement disputes arise.
Canada recently imposed a 1% tax on “vacant or underused housing” owned by non-resident, non-Canadians. The intent was to target foreign investment speculation negatively impacting affordable housing in Canada, but it is impacting good-faith, longtime cottage owners who have maintained and enjoyed living among their Canadian neighbors for years.
Higgins began sounding the alarm about the Underused Housing Tax since it was first proposed in the Government of Canada’s Budget 2021. Most recently, Higgins asked the U.S. Secretary of State to object to the Underused Housing Tax in conversations with the Government of Canada.
Outreach from frustrated U.S. residents has increased in recent weeks as the April 30th tax form deadline approaches in Canada. Congressman Brian Higgins has heard from hundreds of U.S. residents negatively impacted by the Underused Housing Tax, including over 320 property owners who completed an online survey.
Congressman Higgins is a member of the House of Representatives Ways and Means Subcommittee on Trade and serves as Co-Chair of the Northern Border Caucus and the Canada – U.S. Interparliamentary Group. His Western New York district, which includes the Cities of Niagara Falls and Buffalo, borders southern Ontario.
Saturday Mar 11, 2023
Saturday Mar 11, 2023
March 4, 2023 - Participants Include:
Amy Purcell - @Amy_From_Sydney
John Richardson - @Expatriationlaw
This fourth podcast with @Amy_From_Sydney continues with our three discussions from 2022. If you missed either of the first two discussions with her, you can find them here:
First - February 6, 2022:
A fascinating discussion with Amy - born to a US citizen mother in Australia - who has lived in Sydney Australia her whole life. She has visited the United States but has never had any economic connection to the United States. In other words, she is an "Accidental American".
In March of 2021 she received a FATCA inquiry from her Australian bank. In this podcast she describes her "OMG Moment". She generously describes her emotions, her response (getting a Social Security Number) and filing taxes through the streamlined process.
Second - February 22, 2022:
Amy From Sydney Take 2: To Vote Or Not To Vote - That Is The Question, Whether Tis Better To
A fascinating discussion with Amy - born to a US citizen mother in Australia - who has lived in Sydney Australia her whole life. She has visited the United States but has never had any economic connection to the United States. In other words, she is an "Accidental American".
In her first podcast Amy told her story of becoming acquainted with the "Twin Horrors Of FATCA and Taxation Based Citizenship". In this, her second podcast, we continue the discussion with an emphasis on the importance of Americans abroad:
- becoming vocal about the injustices of FATCA and US extraterritorial taxation
- using the right to vote strategically and as an opportunity
- contributing to the struggle by doing what they can!
After all, the United States is actually imposing direct taxation on income earned in Australia by an Australian resident. It's no wonder that Amy describes this as hard to believe and "spacey".
Third - May 24, 2022 - The American Expat Finance News Journal
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Fourth - March 4, 2023
In this 2023 update, Amy provides updates which include:
- the continuing difficulty of advocacy for Americans abroad
- the responsibility of all Americans abroad to participate in the opposition to U.S. extra-territorial overreach
- the continuing conflict between the "Get Out The Vote" initiatives and the interests of @USVotersAbroad
- the importance of fund raising
- why it's important for every country to have at least one "Amy From Sydney"!
- How to become the next "Amy From Sydney!"
Saturday Mar 11, 2023
Saturday Mar 11, 2023
March 11, 2023 - Participants include:
Gregory Smith - @BlogNDog
John Richardson - @Expatriationlaw
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Greg Smith has lived outside the United States for most of his life. He has lived in six U.S. states and 19 different countries. He is presently in Prague where (along with other things) he runs a Hostel for visitors to Prague.
He was previously on the ACA Board.
In this podcast, Greg a wide range of thoughts and perceptions about his 25+ years of living under the tyranny of Mr. FBAR and the U.S. extra-territorial tax, reporting and penalty regime.
This podcast was arranged because of the following Twitter exchange on March 11/23 about the Bittner case:
@Expatriationlaw
Friday Mar 10, 2023
Friday Mar 10, 2023
March 10, 2023 - Participants include:
Keith Redmond - @Keith__Redmond
John Richardson - @Expatriationlaw
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The issue is NOT who should get your vote, but rather how to make the best use of your right to vote. At present ONLY the Democrats have a presence outside the United States and are asking for your vote.
Your right to vote can be used in a variety of different ways which include:
- Voting for either the Republicans or Democrats
- Vote for a small party or third party candidate
- Not vote and ignore the process
- Not vote and explain to the established Parties that you refuse to "Vote For The Party", because (as an American Abroad) the Party won't vote for you!
Friday Mar 10, 2023
Friday Mar 10, 2023
March 10, 2023 - Participants include:
Keith Redmond - @Keith__Redmond
John Richardson - @Expatriationlaw
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For Americans abroad having their "Oh My God Moment" the question is NOT the execution of the plan. The question is what should the plan be!
It's important to RESPOND and NOT to REACT!
Of perhaps view it this way:
‘LET US NOT LOOK BACK IN ANGER, NOR FORWARD IN FEAR, BUT AROUND IN AWARENESS.’ (JAMES THURBER)
Friday Mar 03, 2023
Friday Mar 03, 2023
March 3, 2023 - Participants include:
Keith Redmond - @Keith__Redmond
John Richardson - @Expatriationlaw
In this podcast we discuss:
The United States defines "tax residence" in terms of the "circumstances of birth" rather than the "circumstances of life: and
Why it's important to get the support of other countries in ending the U.S. extra-territorial tax regime!
This discussion is based largely on the following three posts:
https://citizenshipsolutions.ca/2023/01/08/toward-a-definition-of-us-citizenship-taxation/