PREP Podcaster - ”Success Favours The PREPared Mind”

Taxation Without Borders: The Republicans Overseas Proposal To End Citizenship-Based Taxation

July 10, 2024 - Participants include:

 

Vance - @MyLatinLife

John Richardson - @ExpatriationLaw

 

In this episode we discuss the 2024 Republicans Overseas Tax proposal to end U.S. citizenship taxation.

 

AI Description:

"Welcome back to the My Latin Life podcast! Since 2014, we've been your trusted guide to traveling and living in Latin America. In this episode, we reconnect with John Richardson, an expert in expatriation law, to discuss the complexities of American taxation abroad. John is part of SEAT (Stop Extraterritorial American Taxation), an organization advocating for significant changes to the taxation laws affecting Americans living overseas.

Join us as John delves into the latest developments in the fight against citizenship-based taxation. He shares insights on the role of Republicans Overseas in advancing this cause and discusses the potential for legislative and regulatory changes. We explore the complexities of U.S. tax jurisdiction and the impact on Americans who live and work abroad, highlighting the need for reform to align with global standards.

Whether you're a digital nomad or an American expatriate, this episode provides valuable information on how you can get involved in advocating for change. Tune in to learn more about the efforts to sever the link between citizenship and tax residency and the potential implications for the future."

Trump’s Proposal To End Double Taxation Of Americans Abroad Discussed By Tax Academics

October 11, 2024 - Participants include:

 

Dr. Karen Alpert - @FixTheTaxTreaty

Dr. Laura Snyder - @TAPInternation

John Richardson - @Expatriationlaw

 

About SEAT:

 

The purpose of SEAT has been and continues to be to conduct research (including the SEAT survey), prepare position papers, make submissions by SEAT to various governments, facilitate advocacy by individuals impacted, file amicus briefs and provide a centre for educating interested parties about the U.S. extra-territorial tax regime. (SEAT's work may be found on the SEAT website.)

SEAT believes that the problems caused to Americans abroad by the U.S. extraterritorial tax regime can be ended ONLY by severing citizenship from tax residency. We encourage the United States to join the rest of the world by taxing individuals on the basis of residence and source and NOT based on the citizenship of an individual.

This particular podcast is a response to a Tax Notes article discussing the recent Trump proposal to end the double taxation of Americans abroad. The article is found here:

https://www.taxnotes.com/tax-notes-today-federal/financial-reporting/trump-vows-end-double-taxation-overseas-citizens/2024/10/11/7m68f

Of particular interest, and the reason for this podcast, is the following excerpt quoting Professor Avi-Yonah:

 

"Reuven S. Avi-Yonah of the University of Michigan Law School believes concerns over double taxation are exaggerated, noting that in addition to the income exclusion limit and tax credit, many U.S. citizens live in countries that have a tax treaty with the United States, and those treaties often provide “tiebreakers” to ensure there isn’t double income taxation. “Thus, the double taxation argument is spurious,” Avi-Yonah said in an email. “There are many more cases where Americans living overseas enjoy double non-taxation because of sections 911 or 933 than cases of double taxation.”

 

We disagree both the general sentiment expressed and the claim that the treaty tie-break provision is available to U.S. citizens living outside the United States.

 

AI Description:

 

"In this episode, John Richardson from Toronto, Canada, discusses a major proposed development in U.S. taxation policy with Dr. Laura Snyder in Paris and Dr. Karen Alpert in Australia. President Trump's recent announcement to end the double taxation of American citizens abroad has stirred significant interest and controversy. The discussion centers around an article from Tax Notes and the differing perspectives described in the article about this policy shift.

 

Dr. Snyder and Dr. Alpert, both members of the organization "Seat Stop Extraterritorial American Taxation Now," delve into the complexities and implications of the U.S. tax system for Americans living overseas. They critique the views of Professor Ruven Avi-Yonah, who argues that concerns over double taxation are exaggerated and often mitigated by the "treaty tie break" provision tax treaties.

The conversation highlights the challenges faced by expatriates, including definitional and timing issues in tax codes, which can lead to double taxation despite the existence  of tax treaties. The episode calls for more inclusive dialogue involving experts with firsthand experience of these tax challenges, advocating for a reevaluation of the U.S. citizenship-based taxation system."

Ending Double Taxation of Americans Abroad: A Conversation with Solomon Yu on the Future of Citizenship Taxation for Americans Abroad

October 4, 2024 - Participants Include:

 

Solomon Yue - @SolomonYue

 

John Richardson - @ExpatriationLaw

 

Introduction:

 

Republicans Overseas recently announced that President Trump has recognized the unfairness of the tax treatment of Americans abroad and has committed to the principle of eliminating double taxation on them. In this podcast I discuss this message and explore what it means for Americans abroad.

 

AI description:

 

 

"In this engaging episode, host John Richardson reconnects with Solomon Yu, a long-time advocate for ending the double taxation of Americans living overseas. From Toronto to Oregon, the conversation spans continents and decades of activism, as Solomon shares his personal journey from escaping communist China to becoming a key figure in Republican politics and a founder of Republicans Overseas.

Solomon discusses the challenges and triumphs in his decade-long fight against citizenship-based taxation, highlighting the latest breakthrough: a recognition from former President Donald Trump on the need to address this issue. The episode delves into the complexities of U.S. tax laws affecting Americans abroad, the historical context of this advocacy, and the potential impact of Trump's support in the upcoming elections.

Listeners are taken through a narrative of perseverance, legal battles, and political strategy, as Solomon outlines the path forward for Americans overseas. With insights into the political mechanisms at play and a call to action for voting, this episode is a must-listen for anyone interested in the intersection of tax policy, expatriate rights, and American politics."

The Tax Trap: Navigating U.S. Taxation for Americans Abroad

September 4, 2024 - Participants include:

John Alan - @JohnAlanPod

Keith Redmond - @Keith__REDMOND

Anthony Parent - @IRS_Medic

John Richardson - @ExpatriationLaw

 

Note: This podcast was hosted by John Alan and originally was published by him on September 8, 2024 at his John Alan Pod site.

The podcast is reposted here with the kind permission of John Alan.

 

 

AI Description:

 

"Join host John Allen in this episode of "Coming Home with John Allen" as he discusses the complex world of U.S. taxation for Americans living overseas with tax experts John Richardson, Anthony Parent, and Keith Redman. These seasoned professionals dive deep into the intricacies of the U.S. tax code, particularly how it impacts American expats and emigrants.

Discover the distinctions between short-term expats and long-term emigrants, and how the U.S. tax system treats them. The conversation highlights the severe challenges faced by Americans abroad, including the citizenship-based taxation system, the threat of double taxation, and the lack of proper representation and protection.

Learn about the proposed solutions, such as severing U.S. citizenship from tax residency and reforming the current tax regulations. Gain insights from personal experiences and expert advice on how to navigate the tax landscape, mitigate fear, and make informed decisions. This episode is a must-listen for anyone grappling with the complexities of U.S. taxes while living overseas."

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/

 

 

 

 

 

 

I

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."