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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 Mar 14, 2022
For Good And Evil: The Teaching Of Charles Adams Lesson 15
Monday Mar 14, 2022
Monday Mar 14, 2022
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. "

Monday Mar 07, 2022
For Good And Evil: The Teaching Of Charles Adams Lesson 14
Monday Mar 07, 2022
Monday Mar 07, 2022
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."

Friday Mar 04, 2022
A March Sighting Of Mr FBAR - Losing ”Trust” In A Trust
Friday Mar 04, 2022
Friday Mar 04, 2022
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.

Saturday Feb 26, 2022
Americans Abroad Individual Advocacy - Meeting 1: February 25, 2022
Saturday Feb 26, 2022
Saturday Feb 26, 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.

Wednesday Feb 23, 2022
In Mr. FBAR We ”Trust” (pun intended)
Wednesday Feb 23, 2022
Wednesday Feb 23, 2022
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?

Monday Feb 14, 2022
For Good And Evil: The Teaching Of Charles Adams Lesson11
Monday Feb 14, 2022
Monday Feb 14, 2022
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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Friday Feb 11, 2022
Friday Feb 11, 2022
February 11, 2022 - Participants Include:
Amy Purcell - @Amy_From_Sydney
John Richardson - @Expatriationlaw
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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".
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Amy Purcell is a an example of where perseverance and motivation can lead!

Sunday Feb 06, 2022
Sunday Feb 06, 2022
February 6, 2022 - Participants Include:
Amy Purcell - @Amy_From_Sydney
John Richardson - @Expatriationlaw
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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.
Amy then describes her advocacy which included contact with a US based politician. Her description which was posted on Facebook included:
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Friday Feb 04, 2022
Friday Feb 04, 2022
February 4, 2022 - Participants Include:
LJ Eiben - Raymond James - @L_Eiben
John Richardson - @Expatriationlaw
Mr. LJ Eiben first participated as a guest in November of 2021 when we discussed US Social Security for Americans abroad. On January 26, 2002 he returned for a discussion about Canada Pension Plan and Old Age Security.
Today he returns to tell the story of Raymond James and it arose in response to the very real problems experienced by real individuals with ties to both the United States and Canada. LJ describes how Raymond James established itself as a cross broker/investment advisor/financial planner for individuals which include: US citizens living in Canada, Canadians moving to the United States and Green Card holders moving back to Canada. Canadian residents with US IRAs can hold their IRA with Raymond James. Canadians moving to the United States can continue to hold their RRSPs with Raymond James.
The bottom line is that Raymond James allows to those who move between Canada and the United States to keep their investments in one place.
The network of Raymond James advisors is large and growing and advisors are found throughout Canada.
For a description of Raymond James services and some case studies click here.
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Mr. LJ Eiben is a Financial Advisor at Raymond James.
The information in this podcast was obtained from sources RJA and believed to be reliable; however, we cannot represent that it is accurate or complete. It is provided as a general source of information and should not be considered personal investment advice or solicitation to buy or sell securities. The views expressed are not necessarily those of Raymond James (USA) Ltd. Raymond James (USA) Ltd. (RJLU) advisors may only conduct business with residents of the states and/or jurisdictions for which they are properly registered.
Raymond James (USA) Ltd. is a member of FINRA / SIPC
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Wednesday Feb 02, 2022
SEAT Discussion About Residence-BasedTaxation - Who, How, When and Where
Wednesday Feb 02, 2022
Wednesday Feb 02, 2022
February 2, 2022 - Participants Include SEAT Members:
Karen Alpert - @FixTheTaxTreaty
Suzanne Herman - @SuzanneHerman1
Keith Redmond - @Keith__Redmond
John Richardson - @ExpatriationLaw
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This discussion was held to discuss and questions of:
A. What is residence-based taxation; and
B. What is not residence-based taxation
The conversation is divided into the following three modules:
1. What is the difference between definitions of "tax residency" (who is subject to tax) and "worldwide taxation" (what is the scope of income that is taxed?
2. What does SEAT mean by "PureRBT"?
3. There are millions of Americans abroad: Thoughts on how to transition from citizenship-based taxation to PureRBT ...
Thanks to all attendees who participated in the later discussion.