PREP Podcaster - ”Success Favours The PREPared Mind”

The Life And Times Of Andrew Grossman: US Citizenship - A ”Search For Proof” or A ”Search For Truth”?

March 29, 2022 - Participants include:

Andrew Grossman - @AndyGr

John Richardson - @Expatriationlaw

 

For me, the opportunity to speak with Andrew Grossman is a great privilege. Mr. Grossman had a long career in the U.S. Foreign Service having served all around the world. In 1979, he left Tehran approximately 24 hours before the US Embassy was occupied.. In 1985 he dealt with the American citizens who were "caught" up in the TWA hijacking.

Professionally, Mr. Grossman is a superb lawyer with a speciality in citizenship law and how US citizenship law intersects with taxation internationally.

In this podcast we revisit some of my previous discussions with Andrew (see below). He is a prolific researcher in the areas (and intersection) of US citizenship taxation, FATCA and FBAR. Much of his research is consolidated in: "Update: FATCA: Citizenship-Based Taxation, Foreign Asset Reporting Requirements and American Citizens Abroad."

I have previously interviewed Mr. Grossman twice in Montreal:

 

Interview with Andrew Grossman - March 16, 2014 - Montreal, Canada

Catching Up With Andrew Grossman - December 8, 2016 - Montreal, Canada

 

I had the privilege of participating with him in a panel discussion in London here ...

With Solomon Yue, David Treitel and Andrew Grossman - October 8, 2018

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Look for "Part 2" to this podcast in the next few weeks ...

 

 

 

 

Citizenship By Investment: Proud Of Its Past, But How Confident Of Its Future?

March 22, 2022 - Participants Include:

Stephane Tajick - GlobalRCG.com

John Richardson - @Expatriationlaw

More and more people are understanding the importance of "global mobility options". For some people this is a second residence. For some it is a second citizenship. The last decade has witnessed the growth of "Citizenship By Investment".

"Citizenship By Investment" programs allow people to acquire a second citizenship in return for some sort of cash payment. The growth of the industry has generated  opposition to these programs. Citizenship by investment should not be confused with "tax residency". Nevertheless, various governments have taken the position that "citizenship by investment" programs should end. 

The recent Russia/Ukraine conflict has generated sanctions against both Russia and many Russian citizens. Some of the sanctions against Russian citizens have been in the form of denying Russian citizens access to "citizenship by investment". 

My guest, Stephane Tajick, recently wrote an article in the IMI Daily questioning the continued existence of "citizenship by investment" programs. He asks:

"Are We Witnessing The Extinction Of Citizenship By Investment?"

Stephane joins me to discuss this question ...

To Renounce Or Not To Renounce, That Is The Question - How To Make The Renunciation Decision

March 20, 2022 - Participants Include:

 

Karen Alpert - @FixTheTaxTreaty

Keith Redmond - @Keith__Redmond

John Richardson - @Expatriationlaw

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For many people renunciation is a very difficult decision. Citizenship is a part of one's identity. Therefore, the renunciation decision includes many different factors. Some factors (tax, finance and immigration considerations) are objective. Other factors (identity, future plans and impact on family are more subjective.

In this podcast we discuss how these issues may interact and how to be satisfied that you have made an appropriate and defensible decision.

Those interested in a more technical and tax focused discussion of renunciation may find this recent interview/discussion - Renouncing US Citizenship - between John Richardson and Peter Palsen to be of interest.

 

 

 

 

 

How The ”Fair Tax” Would End Tax Residency, Worldwide Income And Taxation Of Americans Abroad

March 17, 2022 - Participants Include:

Jim Bennett - Fair Tax

John Richardson - @Expatriationlaw

 

Albert Einstein famously remarked that:

 

"The hardest thing to understand in the world is the income tax."

 

The income tax may also be the most unfair tax.

 

Fair Tax is a leader in educating and advocating for a "Fair Tax" which imposes taxation on only consumption.

This podcast features a discussion with Jim Bennet who is one of the most focussed and prominent advocates for the "Fair Tax" in the world.

Interestingly, the enactment of the "Fair Tax" would have the unintended consequence of ending the taxation of Americans abroad.

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The concept of the income tax coupled with worldwide taxation means that "tax residents" of a country are subject to taxation on their worldwide income. This leads to enormous complexity, compliance costs, uncertainty, anxiety and unfairness.

Many countries (Canada and the United States) have both an income tax and a consumption based tax. Some countries have only a consumption tax (example Bahamas).

Because of the unfairness, discriminatory nature, complexity and cost of administering an income tax system, there is a movement toward moving toward ONLY a consumption tax system.

Nobody explains this better than Jim Bennett. I thank him for being my guest today.

Learn more about the "Fair Tax" here.

 

 

 

 

For Good And Evil: The Teaching Of Charles Adams Lesson 15

March 14, 2022 - Participants Include:

 

John Richardson - @Expatriationlaw

Jimmy Sexton - @JimmySextonLLM

 

Continuing our podcast series:

For Good And Evil Podcast 1 - October 25, 2021

For Good And Evil Podcast 2 - November 1, 2021

For Good And Evil Podcast 3 - November 8, 2021

For Good And Evil Podcast 4 - November 15, 2021

For Good And Evil Podcast 5 - November 22, 2021

For Good And Evil Podcast 6 - November 29, 2021

For Good And Evil Podcast 7 - December 7, 2021

For Good And Evil Podcast 8 - January 10, 2022

For Good And Evil Podcast 9 - January 17, 2022

For Good And Evil Podcast 10 - January 24, 2002

For Good And Evil Podcast 11 - January 31, 2022

For Good And Evil Podcast 12 - February 7, 2022

For Good And Evil Podcast 13 - February 14, 2022

For Good And Evil Podcast 14 - March 7, 2022

In this episode we continue the teaching of Charles Adams - Lesson 15:

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15. "As taxes increase, evasion increases. "

For Good And Evil: The Teaching Of Charles Adams Lesson 14

March 7, 2022 - Participants Include:

 

John Richardson - @Expatriationlaw

Jimmy Sexton - @JimmySextonLLM

 

Continuing our podcast series:

For Good And Evil Podcast 1 - October 25, 2021

For Good And Evil Podcast 2 - November 1, 2021

For Good And Evil Podcast 3 - November 8, 2021

For Good And Evil Podcast 4 - November 15, 2021

For Good And Evil Podcast 5 - November 22, 2021

For Good And Evil Podcast 6 - November 29, 2021

For Good And Evil Podcast 7 - December 7, 2021

For Good And Evil Podcast 8 - January 10, 2022

For Good And Evil Podcast 9 - January 17, 2022

For Good And Evil Podcast 10 - January 24, 2002

For Good And Evil Podcast 11 - January 31, 2022

For Good And Evil Podcast 12 - February 7, 2022

For Good And Evil Podcast 13 - February 14, 2022

In this episode we continue the teaching of Charles Adams - Lesson 14:

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14. " Wars produce new taxes and high tax rates, but when the emergency ends, governments will try to retain their newly enlarged taxing powers."

 

A March Sighting Of Mr FBAR - Losing ”Trust” In A Trust

March 4, 2022 - Participants Include:

Virginia La Torre Jeker - @VLJeker

John Richardson - @Expatriationlaw

 

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On February 23, 2002 I had the privilege of speaking with noted FBARologist Virginia La Torre Jeker. In that podcast we discussed the FBAR obligations that attach to a trust itself.  This podcast explores when the individuals who are part of the trust (settlor, trustee and beneficiaries) have FBAR obligations because of their relationship to the trust.  This podcast is based largely on Virginia's post published on March 3, 2022 which discussed this important issue.

A surprising realization is that there are circumstances when a beneficiary of a trust will not know and cannot know whether they have an FBAR obligation.

 

 

Americans Abroad Individual Advocacy - Meeting 1: February 25, 2022

February 25, 2022 - Participants Include:

 

Karen Alpert - @FixTheTaxTreaty

 

John Richardson - @Expatriationlaw

 

On February 25, 2022 Karen Alpert and John Richardson of SEAT hosted a meeting for individuals who were interested in how to advocate for tax changes for Americans abroad.

In general terms the podcast focussed on the necessity of individual advocacy and aligning with the common message of severing citizenship from tax residency.

This podcast is a recording of part of the discussion. After the podcast the recording ceased and the group engaged in general discussion.

These meetings will continue periodically.

You can find the outline for the meeting here.

In Mr. FBAR We ”Trust” (pun intended)

February 23, 2022 - Participants Include:

Virginia La Torre Jeker - @VLJeker

John Richardson - @Expatriationlaw

Prologue - Report Early! Report Often! Report Everything! Keep A Record Of What You Report!

In October of 2018, Virginia and I went "Looking For Mr. FBAR." During the last three years we have uncovered many clues, we have learned many things, but it's clear that we have not yet located Mr. FBAR. Virginia has written about many of her "sightings" in a series of "FBAR posts". I have also written a number of posts documenting the various adventures of Mr. FBAR.

Mr. FBAR is elusive. He is is simultaneously not anywhere, but everywhere. There is no weapon in the US arsenal of forms that has created such fear and uncertainty. He has even threatened certain visitors to the United States for the failure to file an FBAR.

Legal Authorization

The statutory authorization which gave birth to Mr. FBAR is found in 5314 of the Bank Secrecy Act. Most of the substantive law is found in Treasury Regulations and the IRS instructions. It's important to note that Mr. FBAR lives in Title 31 (Bank Secrecy Act) which is different from Title 26 (Internal Revenue Code).

Mr. FBAR And The Filing Obligations Of Trusts

This podcast is a discussion of how Mr. FBAR impacts "trusts". When is a trust a United States person? When must a trust file an FBAR to report the "financial accounts" of a related purpose of entity?

 

 

 

 

 

 

For Good And Evil: The Teaching Of Charles Adams Lesson11

January 31, 2022 - Participants Include:

 

John Richardson - @Expatriationlaw

Jimmy Sexton - @JimmySextonLLM

 

Continuing our podcast series:

For Good And Evil Podcast 1 - October 25, 2021

For Good And Evil Podcast 2 - November 1, 2021

For Good And Evil Podcast 3 - November 8, 2021

For Good And Evil Podcast 4 - November 15, 2021

For Good And Evil Podcast 5 - November 22, 2021

For Good And Evil Podcast 6 - November 29, 2021

For Good And Evil Podcast 7 - December 7, 2021

For Good And Evil Podcast 8 - January 10, 2022

For Good And Evil Podcast 9 - January 17, 2022

For Good And Evil Podcast 10 - January 24, 2002

 

In this episode we continue the teaching of Charles Adams - Lesson 11:

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11. "If liberty is to be defended with success against the dominance of the state, then financial privacy must be preserved. Banking privacy is one of the cornerstones of liberty, having its roots in the early principle of English law that a man's castle (primarily his treasury) is beyond the surveillance of the King."

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