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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 ...
Monday Jan 31, 2022
Monday Jan 31, 2022
January 29, 2022 - Participants Include:
Athena Mason - OurVoices.party
Marc Mixon - OurVoices.party
John Richardson - @Independents
Joe Howard - @JustJoe12345678
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This Joe Is No Ordinary Joe!
Democracy Is NOT A Spectator Sport!!
On December 23, 2021 I was joined by Joe Howard to discuss how Americans abroad can become part of "democratic renewal in America". This is a continuation of our discussion. We are joined by Athena Mason and Marc Nixon. Both Athena and Marc are leaders in the movement to create a democracy in America where the interests of all Americans are considered. You are invited to connect with Athena and Marc at OurVoices.party.
The description to the December 23, 2021 podcast included:
There are two groups of Americans whose interests are not considered in the political process.
Group 1 - Americans Abroad: US citizens living outside the USA who are very much aware that their interests are not represented.
Group 2 - Resident Americans: US citizens living inside the USA who (although able to vote) do not have the opportunity to vote for candidates who represent their interests. They are increasingly becoming aware that their interests are not represented.
Unfortunately the US political process is run for and only for the mainstream political parties. Neither party has either awareness or concern for the interests of Americans abroad. To put it simply:
"It's not they don't care. It's that they don't care that they don't care!"
There is no short term solution to the "PartyOcracy" of US politics. In the long run "Democracy In America" will survive only with the creation of new political parties and through the rise of independent candidates. This is the only way to nourish candidates who represent the interests of the voters rather than the interests of the parties.
In today's podcast I had the opportunity to speak with Joe Howard. Joe is an American (with an interesting background) living in Thailand where he teaches English and Physical Education. He is also working on a Masters in Education through the University Of The People.
Joe is doing what no expat or group has done before. He is working with new political parties to ensure that the interests of Americans abroad are represented and that pure residence-based taxation is part of the agenda/platform.
He is currently working with the "United People's Assembly" which is creating an Americans Abroad caucus. With or without changes in US tax policy it is essential that the interests of Americans abroad find a home in the US political process.
Americans abroad are good at complaining and bad about taking specific steps to help their situation. You are invited to ride on Joe's work. All that is required is that you support democratic renewal for Americans abroad!
United People's Assembly (Guilded) is getting organized. The Guilded link is an invite link.
https://www.guilded.gg/r/zzARmrndBl?i=AnbwnlXA
You can (and should) contact Joe at:
american.expat.rbt@gmail.com
Remember, This Joe Is No Ordinary Joe!
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To learn more about the "University of the People" (an amazing initiative)
https://www.uopeople.edu/
Friday Jan 28, 2022
Friday Jan 28, 2022
January 28, 2022 - Participants Include:
John Richardson - @Expatriationlaw
Hamza Assyad - A Green Card Holder Living In The USA - @AssyadHamza
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Renouncing US Citizenship:
On January 14, 2022 my podcast guest was Max. Max was born a dual citizen who moved from the USA - as a young adult to Germany - and renounced his US citizenship. It was a particularly interesting discussion because of the reason Max offered as leading to the renunciation decision. After a great amount of research, reflection, deliberation Max determined that his US citizenship made it impossible to engage in normal financial and retirement planning. You can listen to the "Max Podcast" here.
Abandoning The Green Card:
Shortly after the "Max Podcast" I was contacted by Hamza who offered to describe why:
1. As a Green Card holder living in the USA he had chosen to NOT naturalize as a US citizen; and
2. Why he was planning to move from the United States before he would be subject to the US 877A Expatriation Tax (becoming a "long term resident" who was a "covered expatriate").
Hamza's decision was informed by the fact that he did NOT plan to live in the United States permanently and therefore could not risk staying too long.
Today's podcast with Hamza was particularly interesting because it also includes a comparison between the US 877A Exit Tax and Canada's Departure tax. (Hamza was a "permanent resident" of Canada before moving to the United States and receiving a Green Card.)
Throughout history the United States has benefitted greatly from immigration to the United States. Hamza is part of a young, dynamic and skilled generation of Green Card holders who believe it is too risky to live permanently in the United States or to live as a US citizen.
Wednesday Jan 26, 2022
Wednesday Jan 26, 2022
January 26, 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. Today he returns for a discussion about Canada Pension Plan and Old Age Security.
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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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Financial planning has become a necessity for all individuals and families. US citizens living outside the United States face particularly difficult hurdles. Much of this is the result of the requirement of filing taxes in both Canada and the United States. What one tax system gives, the other taxes. As a result, it is essential that US citizens receive specialized financial, investment, tax (and even life) advice. In general the receipt of US Social Security is NOT dependent on being a US citizen. Hence it is available to all individuals who "paid into the system" without regard to citizenship. It is available to Green Card holders returning home, US citizens living abroad and those who renounced US citizenship.
Raymond James as a "cross border platform" which means that (in general) it can hold US investments in Canada for Canadians.
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Canada Pension Plan And Financial Planning:
When it comes to Canada Pension Plan it's important to NOT leave money on the table. In this podcast Mr. Eiben gives his reasons for why it may make sense to delay receiving Canada Pension Plan to age 70 which will result in significantly higher payments. In addition, those higher payments will result in higher spousal/retirement benefits!
Wednesday Jan 26, 2022
Wednesday Jan 26, 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
In this episode we continue the teaching of Charles Adams - Lesson 10:
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10. "Tax exemptions are inherently unjust unless they actually apply to everyone. If the constitutional principle of equality before the law is ever applied to taxation, then those in control of tax making must bear the same taxes as those on the outside. This means that in an aristocracy or oligarchy, the few would have to bear the same taxes as the many, and in a democracy, the many should bear the same taxes as the few."
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Sunday Jan 23, 2022
Sunday Jan 23, 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
In this episode we continue the teaching of Charles Adams - Lesson 9:
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9. "Consent is required for all lawful taxation, either by long-standing custom or by the common consent of the taxpayer. When a state taxes without bona fide consent, regardless of the equities or the reasonableness of the tax, rebellion and civil disobedience are justified."
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Sunday Jan 23, 2022
Sunday Jan 23, 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
In this episode we continue the teaching of Charles Adams - Lesson 8:
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8. "Taxpayer discontent threatens the peace and prosperity of the social order, more so than misbehaving taxpayers do; consequently the criminal arm of the tax system should be directed against oppressive tax agents rather than angry taxpayers."
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Friday Jan 21, 2022
Friday Jan 21, 2022
January 21, 2022 - Participants include:
John Richardson - @Expatriationlaw
Jim Gosart - Vice-President Republicans Overseas
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Attention! We are entering "International Waters"! US Citizens be advised that you may now be subject to double taxation!
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To Whom Much Has Been Given, Much Is Expected!!
Yes, it's true! A US citizen, because and only because of the combination of US citizenship-based taxation coupled with living outside the United States, is likely to be subject to double taxation. The following discussion explains why.
Part A: Introduction – About Citizenship-based Taxation
Part B: How the Internal Revenue Code is designed to mitigate the effects of double taxation in certain circumstances
Part C: Determining what is “foreign source” income
Part D: The problem of international waters …
Part E: The effect of sourcing to the US income earned in international waters by dual tax residents
Part F: Deducting “foreign taxes” paid – although income from international waters may not be foreign, it is still subject to the payment of “foreign taxes”
Part G: Can a US citizen living abroad be saved by a tax treaty? Maybe if he/she lives in Canada****
Part H: Conclusion and the need for “Pure Residence-Based Taxation”
You can read the horrible details here ...
Friday Jan 14, 2022
Friday Jan 14, 2022
January 14, 2022 - Participants Include:
John Richardson - @Expatriationlaw
Max - A former US citizen residing in Germany
The value of US citizenship depends largely on your age. As a general principle, I believe that the value of US citizenship is inversely correlated with age. US citizenship is more valuable to younger people who are in the process of building their careers. After all, there are many job and career opportunities in the United States. The younger you are, the more valuable US citizenship is.
As of late, I am seeing more and more people in their twenties considering renouncing US citizenship. After "tweeting" this trend, Max (a resident of Germany) contacted me and expressed his willingness to explain his reasons for renouncing.
This podcast is a very lucid description of why middle class people living outside the United States are renouncing US citizenship. I suggest that it be spread far and wide!
A special thanks to Max for sharing!
Monday Jan 10, 2022
Monday Jan 10, 2022
January 10, 2022 - Participants Include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
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The Issue:
Is the expatriate required to certify that he is in compliance at the moment of expatriation? Can compliance problems be fixed after expatriation?
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Who Is A Covered Expatriate? - The Statute
The Covered Expatriate - IRC 877(a)(2)
(2)Individuals subject to this section This section shall apply to any individual if—
Sunday Jan 09, 2022
Sunday Jan 09, 2022
January 7, 2022 - Participants Include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
The Background - An Exclusion From Capital Gains
Internal Revenue Code Section 121 provides (in certain circumstances) a $250,000 exclusion from taxation on the capital gain on the sale of a principal residence.
Covered Expatriates, The Exit Tax and "Deemed Capital Gains"
When a covered expatriate renounces US citizenship he/she is subject to a capital gains tax based on the deemed sale of all property. Specifically 877A includes:
All property of a covered expatriate shall be treated as sold on the day before the expatriation date for its fair market value.
The Issue:
Do the words "notwithstanding any other provision of this title" mean that the S. 121 exclusion is not available to "covered expatriates" renouncing US citizenship?
On January 6, 2022 Dubai based US tax lawyer wrote a post discussing this issue:
https://us-tax.org/2022/01/06/covered-expatriates-exit-tax-and-the-principal-residence/
On January 7, 2022 Virginia joined me to explore this issue in this podcast.
