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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
Wednesday Aug 07, 2024
Wednesday Aug 07, 2024
August 7, 2024 - Participants include:
Tim Symth - @TPSymth01
John Richardson - @ExpatriationLaw
AI Description:
"Join John Richardson from Toronto, Canada, as he continues his insightful discussion with Tim Symth from Boston. In this episode, they delve into the complexities faced by U.S. retirees living abroad and the potential impacts for "retirees abroad" of transitioning from a citizenship-based tax system to a residency-based taxation system.
John and Tim clarify the definition of a "retiree abroad" and explore the tax obligations these individuals face under the current U.S. citizenship-based taxation system. They discuss the fears and concerns associated with a shift to residency-based taxation, particularly drawing comparisons with the Canadian tax model.
The conversation highlights how U.S. retirees abroad, who primarily have U.S. source income, navigate their tax responsibilities and why they may not be motivated to support a change to residency-based taxation. Tune in for an in-depth analysis of the tax implications for U.S. citizens retiring overseas and the broader debate on taxation systems."
Wednesday Jul 31, 2024
Wednesday Jul 31, 2024
July 31, 2024 - Participants include:
Tim Symth - @TPSymth01
John Richardson - @ExpatriationLaw
Laura Snyder: - @TAPInternation (providing the reason for the podcast)
Prologue:
A message rom Laura Snyder:
https://x.com/TAPInternation/status/1818299155275563265
AI description:
"In this episode, John Richardson from Toronto, Canada, reconnects with Tim Smyth from Boston to discuss the intriguing topic of citizenship-based taxation. As a long-time advocate for residency-based taxation for Americans abroad, Tim brings his insights on the recent political buzz in France about adopting citizenship-based taxation similar to the United States.
John and Tim delve into the historical context of tax treaties, the implications of France's extensive network of treaties, and why these treaties pose significant obstacles to France's proposed tax policy. They also explore the potential consequences for global tax sovereignty and the United States' unique position in the world of international taxation.
Tune in to understand the complexities behind France's ambitious tax proposal, the legal and constitutional challenges it faces, and the broader implications for global mobility and taxation."
Saturday Jul 27, 2024
Saturday Jul 27, 2024
July 27, 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. It's Saturday morning, July 27, 2024, and I am continuing my discussion today with U.S. tax lawyer Virginia LaTorre Jeker.
Virginia recently wrote a fascinating article that appeared in Forbes, titled "The Scary Truth About Navigating IRS Tax Guidance." In this episode, we dive into the implications of her findings for Americans abroad and their U.S. tax compliance.
Virginia shares insights on the pitfalls of relying on IRS online instructions and publications, explaining why these might not be as authoritative as taxpayers believe. We discuss the importance of the Internal Revenue Bulletin and how it differs from other IRS publications.
We also explore practical advice for taxpayers facing penalties and the potential use of the Taxpayer Bill of Rights as a defense. This episode is essential listening for anyone grappling with U.S. tax issues, especially those living overseas.
For more of Virginia's wisdom and experience, visit her blog at us-tax.org."
Sunday Jul 21, 2024
Sunday Jul 21, 2024
July 12, 2024 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @ExpatriationLaw
AI Description:
"Join John Richardson from Toronto, Canada, as he engages in an insightful discussion with Virginia LaTorre-Jeker, a renowned lawyer, author, and blogger. Recorded on Friday, July 12, 2024, this episode delves into the complexities faced by taxpayers, particularly those living abroad, when dealing with tax return preparers.
In this episode, Virginia highlights key points from her recent Forbes article, "Tax Return Preparers' Mistakes or Fraud? Innocent Taxpayer Takes the Hit." The conversation covers the vulnerabilities of taxpayers to fraudulent or incompetent tax preparers, especially for Americans abroad dealing with different currencies and complex tax systems.
They discuss the importance of due diligence in selecting a tax preparer, the concept of reasonable cause for penalty mitigation, and the extended statute of limitations for international taxpayers. Virginia provides practical advice for those who find themselves in a situation where their tax returns have been mishandled, emphasizing the need to act promptly and seek professional guidance.
This episode is a must-listen for anyone looking to understand the intricacies of tax preparation and safeguard against potential pitfalls."
Sunday Jun 30, 2024
Sunday Jun 30, 2024
June 30, 2024 - participants include:
Diana - @DianasPlace
John Richardson - @ExpatriationLaw
AI generated description:
"In this final June podcast, John Richardson from Toronto, Canada, sits down with Diana, an Ontario resident who shares her harrowing experience with the U.S. tax system via her green card. On the eve of Canada Day, Diana recounts her journey through the bureaucratic maze, the unexpected financial burdens, and the emotional toll of striving for compliance. From the infamous "name and shame" list to the complexities of tax obligations, Diana's story sheds light on the lesser-known challenges faced by those entangled in the U.S. tax system.
Tune in to hear about her ultimate escape to a "form-free" life and her advice for anyone considering marrying an American."
Saturday Jun 29, 2024
Saturday Jun 29, 2024
June 29, 2024 - Participants include:
Jim Bennett- Fair Tax
Steven Hayes Fair Tax
John Richardson - @ExpatriationLaw
I have previously hosted Jim Bennett and Steve Hayes of Fair Tax fame. Previous podcasts are available here. Much has happened since our last discussion.
The June 20, 2024 Supreme Court ruling in Moore v. U.S. demonstrates that it's time for taxation to return to its original purpose of raising revenue.
Notably the Fair Tax would accomplish two goals:
1. It would turn the United States into a territorial tax system (the U.S. would NOT income/events outside the United States; and
2. It would replace the compliance costs and weaponisation of the income tax with a simpler (and likely more fair) sales tax.
AI Description
"Join John Richardson from Toronto, Canada, as he welcomes back Jim Bennett and Steve Hayes from Fairtax.org. In this engaging episode, they dive into the implications of the recent Moore decision and its potential impact on the future of the fair tax. Discover how the fair tax could change the landscape of U.S. taxation, promoting personal responsibility and reducing government overreach. This conversation is essential for anyone interested in the intersection of tax policy and personal freedom.
Learn about the fundamental differences between the current income tax system and the proposed fair tax, and why it might be crucial for a healthy, functioning democracy. Don’t miss this insightful discussion that touches on historical perspectives, legal intricacies, and the practical benefits of a consumption-based tax system."
Tuesday Jun 25, 2024
Tuesday Jun 25, 2024
SEAT has prepared a new survey and is asking both current and former Americans abroad to participate. Advocacy for Americans abroad is greatly enhanced by the availability of current information. The survey is on the SEAT site:
https://seatnow.org/2024/06/14/tell-your-story/
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June 25, 2025 - Participants include:
Dr. Karen Alpert - @FixTheTaxTreaty
Anthony Parent - @IRS_Medic
Keith Redmond - @Keith__Redmond
Dr. Laura Snyder - @TAPInternation
John Richardson - @Expatriationlaw
AI Description:
"Join John Richardson and a panel of experts as they dissect the recent Harvard Law Review note that attempts to defend the constitutionality of the U.S. Exit Tax. The episode features Anthony Parent from the IRS Medic podcast, along with SEAT members and co-founders Keith Redmond, Karen Alpert, and Laura Snyder.
The discussion kicks off with an overview of the Exit Tax, a levy imposed on Americans renouncing their citizenship to escape U.S. taxation. The panel critiques the Harvard note for its factual inaccuracies and defamatory statements about Americans living abroad. They argue that the article misrepresents the reasons behind renunciations and fails to consider the complex compliance issues faced by expatriates.
Further, the conversation explores the broader implications of the Harvard Law Review's stance, the need for severing citizenship from tax residency, and the potential unconstitutionality of the Exit Tax post-Moore decision. The panel also highlights the importance of advocating for the complete severance of citizenship from tax residency to solve the problems faced by Americans abroad.
Tune in for an insightful debate on the flaws in the Harvard Law Review note and the broader issues of U.S. taxation on expatriates."
Thursday Jun 20, 2024
Thursday Jun 20, 2024
June 20, 2024 - Participants include:
Dr. Laura Snyder - @TAPInternation
John Richardson - @Expatriationlaw
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.
Part of SEAT's work has been break our research into specific issues and categories. These categories are expressed as "SEAT Working Papers". In order to make the "SEAT Working Papers" available in podcast form, SEAT co-founders Karen Alpert, Laura Snyder and John Richardson are developing a series of podcasts - featuring interactive discussion - where we distill the "working paper" into conversational format. It is our hope that these podcasts will make SEAT's content available to a larger group of people.
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Today on June 20, 2024 the Supreme Court of the United States released its decision in the Moore Transition Tax case. The court ruled 7 to 2 against with Moores with Justices Thomas and Gorsuch dissenting.
In this podcast Laura Snyder and I discuss our impressions (it's only been out for a few hours) of the Court's decision.
Individuals were the owners of far more CFCs than multinationals. A large percentage of CFCs owned by individuals are owned by Americans abroad. Individuals were not mentioned in the decision.
Therefore, it is clear that those Americans abroad who are considering renunciation should renounce as soon as reasonably possible!! It is simply too risky to retain your U.S. citizenship and live outside the United States.
In spite of the seven to two ruling against the Moores, I regard the decision as:
A short run loss for the Moores and a possible long run win for taxpayers. My reasoning is detailed in the following tweets ...
https://x.com/ExpatriationLaw/status/1803808588797780417
https://x.com/ExpatriationLaw/status/1803794413639926061
Generally four of the nine justices suggested that taxation may be subject to certain constitutional - due process - limitations. The remaining five justices did NOT discuss any limitations on taxation.
The full decision is may be read here:
https://www.supremecourt.gov/opinions/23pdf/22-800_jg6o.pdf
Previous SEAT podcasts about Moore include:
https://prep.podbean.com/e/december-5-2023-debriefing-the-moore-case-what-happened-at-the-hearing/
https://prep.podbean.com/e/moore-v-united-states-december-5-2023-the-argument-before-the-court/
Thursday Jun 13, 2024
Thursday Jun 13, 2024
June 13, 2024 - Participants include:
Dr. Karen Alpert - @FixTheTaxTreaty
Dr. Laura Snyder - @TAPInternation
John Richardson - @Expatriationlaw
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.
Part of SEAT's work has been break our research into specific issues and categories. These categories are expressed as "SEAT Working Papers". In order to make the "SEAT Working Papers" available in podcast form, SEAT co-founders Karen Alpert, Laura Snyder and John Richardson are developing a series of podcasts - featuring interactive discussion - where we distill the "working paper" into conversational format. It is our hope that these podcasts will make SEAT's content available to a larger group of people.
Laura's newest paper is titled:
"The Invisibility Of The American Emigrant"
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4832126
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AI Description:
"Join John Richardson from Toronto, Canada, as he delves into the struggles of U.S. citizens living abroad with Dr. Laura Snyder from Paris and Dr. Karen Alpert from Australia. This episode focuses on Laura Snyder's compelling paper, "The Invisibility of the American Emigrant," which highlights the systemic issues that overseas Americans face, particularly concerning taxation and banking policies.
The discussion explores how American expatriates are ignored or belittled by U.S. policymakers and academics, despite their continuous efforts to communicate their challenges. The episode also examines the complexities of filing U.S. tax returns from abroad, the role of the tax preparation industry, and the lack of IRS resources dedicated to serving Americans overseas.
Listen in as the guests provide insightful commentary on the broader implications of these issues, including how they affect not only those who identify as Americans but also those who may not even realize their U.S. citizenship status. The episode concludes with a discussion on potential solutions and the need for systemic change."
Tuesday Jun 11, 2024
Tuesday Jun 11, 2024
June 11, 2024 - Participants include:
Dr. Karen Alpert - @FixTheTaxTreaty
Dr. Laura Snyder - @TAPInternation
John Richardson - @Expatriationlaw
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.
Part of SEAT's work has been break our research into specific issues and categories. These categories are expressed as "SEAT Working Papers". In order to make the "SEAT Working Papers" available in podcast form, SEAT co-founders Karen Alpert, Laura Snyder and John Richardson are developing a series of podcasts - featuring interactive discussion - where we distill the "working paper" into conversational format. It is our hope that these podcasts will make SEAT's content available to a larger group of people.
______________________________________
AI conversion:
"Good morning from Toronto, Canada! Join John Richardson, Laura Snyder in Paris, and Karen Alpert in Australia as they discuss the launch of a new and vital survey targeting overseas Americans. Laura shares insights on past surveys from 2019 and 2021, and why it’s crucial to update this data to reflect current experiences.
They highlight the importance of participation, emphasizing that the survey is open to both current and former U.S. citizens living abroad. By contributing, individuals help in addressing issues like citizenship taxation and more, providing invaluable data that informs future research and policy.
Discover how this survey aims to capture a comprehensive view of the overseas American experience and the steps being taken to ensure wide dissemination and participation. The team underscores the survey's anonymity and how participants can expect their data to be handled securely.
Tune in to learn how you can contribute to this important initiative and make a difference for Americans living abroad. For more details, visit the SEAT website at seatnow.org."