PREP Podcaster - ”Success Favours The PREPared Mind”

Treaty vs. Tax: Can a Canadian Credit Offset the U.S. Net Investment Income Tax?

January 9, 2025 - Based on the Amicus Brief filed by Professors Rosenbloom and Shaheen in support of the argument that the Canada U.S. tax treaty DOES require the United States to allow a credit against the Net Investment Income Tax ("NIIT") for taxes paid to Canada.

 

"This episode examines Bruyea v. United States, focusing on whether a U.S. citizen living in Canada can use Canadian tax credits against the U.S. Net Investment Income Tax (NIIT), and how a single treaty phrase — “subject to the limitations” — has spawned a major legal dispute.

Featuring analysis from treaty negotiator H. David Rosenbloom and Professor Fadi Shaheen, the episode breaks down the government’s Chapter 2A argument, the treaty’s intent to prevent double taxation, and the broader diplomatic and legal stakes of interpreting the U.S.-Canada tax treaty."

Emergency in The Hague: When the ICJ was Asked to Stop a Hostage Crisis

January 5, 2026: AI Generated podcast based on Attorney General Benjamin Civiletti's 1979 argument in the International Court when the U.S. Embassy was seized in Iran.

Mr. Civiletti's statement to the court is here:

 

https://www.justice.gov/sites/default/files/ag/legacy/2011/08/23/12-10-1979.pdf

 

Here is the AI description of the statement ...

 

"On December 10, 1979, the United States asked the International Court of Justice for urgent provisional measures to end the illegal seizure and imprisonment of American diplomats in Tehran. Led by Attorney General Benjamin Civiletti, the U.S. framed the plea as an emergency injunction grounded in law, not politics.

The episode traces the four-pronged legal strategy—Vienna Conventions on Diplomatic and Consular Relations, the 1973 convention on Crimes Against Internationally Protected Persons, and the 1955 U.S.–Iran Treaty of Amity—and shows how the case sought to protect individual lives while defending the foundations of the international diplomatic system."

 

Fee, Fines, and Forced Farewells: The Hidden Toll on Americans Abroad

January 2, 2026 - AI generated podcast from upcoming post written by John Richardson at The Isaac Brock Society.

 

"In this episode of The Deep Dive we unpack the three-year delay in reducing the Certificate of Loss of Nationality (CLN) fee and what that delay reveals about the U.S. government's treatment of Americans living abroad.

Using public comments, legal precedent, and a breakdown of three exit taxes—the CLN fee, the 877A expatriation tax, and the 2801 covered gift tax—we show how citizenship taxation and reporting requirements can coerce people into renouncing and even punish their heirs.

We also examine the constitutional questions raised by Afroyim v. Rusk, the bureaucratic path of the fee reduction, and why lowering the administrative fee alone may not address the deeper systemic problems driving Americans to give up their citizenship."

Safety vs. Subsidy: FAA’s 90-Day Safety Mandate For Airplances vs. A Proposed Fee Cut To Issue A Certificate Of Loss Of Nationality

December 29, 2025 - AI Generated

This is an AI generated podcast which describes the Rule Making Notice which appeared in the Federal Register on October 2, 2023. This notice describes the Rule Making undertaken by the State Department to reduce the fee to process a Certificate of Loss of Nationality from $2350 to $450 (where it was in 2014).

A link to the Federal Register is:

https://www.govinfo.gov/content/pkg/FR-2023-10-02/pdf/2023-21559.pdf

 

 

"This episode contrasts two federal actions from the October 2, 2023 Federal Register: an FAA airworthiness directive forcing U.S. operators of certain older Airbus A300 variants to implement new structural maintenance limits within 90 days to address fatigue and reduced structural integrity, and a State Department proposed rule cutting the Certificate of Loss of Nationality fee from $2,350 to $450 to reduce financial deterrence, costing the Treasury about $8.8 million annually.

It explores how safety imperatives can make cost irrelevant while policy choices can justify deliberate subsidies, and asks where the government should draw the line between technical necessity and political priorities."

Moreno Bill Fallout: Dual Citizens Could Lose U.S. Status and Face Exit Taxes

December 8, 2025 - Participants include:

 

Virginia La Torre Jeker - @VLJeker

 

John Richardson - @ExpatriationLaw

 

 

"Hosts John Richardson and Virginia La Torre Jeker unpack Senator Moreno's proposed bill to eliminate dual citizenship and the practical effects it could have if enacted.

They explain the tax risks, including the exit tax and "covered expatriate" rules, how Social Security payments and benefits for expatriates could be affected, special concerns for Native American tribes, and possible diplomatic complications.

The conversation highlights legal uncertainties, real-life consequences for dual nationals and Americans abroad, and the likelihood of ongoing debate and pushback."

Uprooting Dual Citizens: The Exclusive Citizenship Act Explained

December 3, 2025 - Participants include:

 

Virginia La Torre Jeker - @VLJeker

 

John Richardson - @ExpatriationLaw

 

This podcast is based on Virginia's Forbes article - "Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship" - which appeared on December 3, 2025.

 

AI generated description:

"Host John Richardson and U.S. tax lawyer Virginia La Torre Jeker  discuss the "Exclusive Citizenship Act of 2025", a proposed law that would force dual citizens to renounce foreign citizenship or lose U.S. citizenship within a year, and bar future dual nationality.

The episode reviews Supreme Court precedent (Afroyim v. Rusk and Vance v. Terrazas), constitutional concerns about involuntary expatriation, who would be affected (naturalized citizens, children with dual nationality, spouses, long-term expatriates), and potentially severe tax consequences including the exit tax."

Exclusive Citizenship Act 2025: Is Dual Citizenship Over?

December 3, 2025 - Participants include:

 

Parviz Malakouti - @ParvizMalakouti

 

Brent Vanderbrook - @Vanderbrook

 

John Richardson - @ExpatriationLaw

 

This podcast of an X.com "Space" that took place on December 3, 2025. Here it is:

 

https://x.com/ParvizMalakouti/status/1995905374034297232

 

 

"Citizenship and Immigration Attorney Parviz Malakouti breaks down Ohio Senator Bernie Moreno's "Exclusive Citizenship Act of 2025", a bill proposing a blanket prohibition on U.S. dual citizenship. The episode explains key provisions — how foreign citizenship is defined, automatic relinquishment after acquiring another nationality, a one-year deadline for existing dual citizens to renounce one citizenship, and proposed enforcement and record-keeping measures.

Malakouki and guests discuss the bill's constitutional and legal weaknesses, possible tax consequences (including triggering the exit tax), who would be most affected (those who naturalized as citizens of another country, hidden dual citizens, and Americans abroad), and broader privacy and policy implications. They assess the bill's low immediate chance of passage but warn of its dangerous precedent and call for continued public attention and advocacy."

FBAR at 55: How a Cold War Rule Became an Expat Crisis

November 20, 2025 - An AI generated podcast from a John Richardson presentation with IRS Medic.

 

AI generated summary:

 

"This episode unpacks FBAR—from its 1970 origins under the Bank Secrecy Act to today’s wide reporting net that catches signing authority, beneficial ownership, and many routine foreign accounts.

We explain the filing threshold, how FBAR differs from IRS information forms, the discretionary power Treasury holds to exempt Americans abroad, and why civil and criminal penalties can be severe enough to ruin lives or push people to renounce citizenship."

Parviz Malakouti - Space 50 - November 13, 2025 - Afroyim v. Rusk

November 13, 2025 - Participants include:

 

Parviz Malakouti - @ParvizMalakouti

Brent Vanderbook - @Vanderbrook

John Richardson - @ExpatriationLaw

 

Information, reason and the outline of the "Space" is here:

 

https://x.com/ParvizMalakouti/status/1986483363931431382

 

 

Citizenship Apartheid: How Birthright Builds a Global Caste

November 11, 2025

 

Citizenship Apartheid - Paper by Professor Dimitry Kochenov

 

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4680018

 

This podcast is based on Professor Kochenov's thought provoking paper.

 

AI description:

"In this episode we unpack a provocative argument: modern citizenship functions as a form of global apartheid, sorting people by birthright into zones of opportunity and exclusion. The sources argue that passports operate as a blood-based aristocracy, granting vast privileges to a minority while trapping the majority behind steep visa walls.

We trace the system’s colonial roots, explore compensatory citizenship and regional intercitizenships, and ask whether freedom of movement—not voting—is the fundamental right at stake. The episode challenges the rhetoric of universal rights by showing how nationality often determines life chances."