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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 Mar 06, 2024
Insights on Boosting Immunity to fight the common cold with Health Coach David Coutts
Wednesday Mar 06, 2024
Wednesday Mar 06, 2024
March 6, 2024 - Participants Include:
David (Coach) Coutts - @RealCoachCoutts
John Richardson - @Expatriationlaw
Coach Coutts - Leave The Cold Recovery to US!
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AI Description ...
"In this invigorating episode of our health-focused podcast, host John Richardson sits down with return guest and renowned health coach, David Coutts, for a deep dive into managing and recovering from common colds naturally. Releasing intriguing information, David reveals his secrets for staying free of sickness for nearly a decade and presents practical methods for recognizing and counteracting the early signs of a cold.
Exploring a variety of natural remedies, David shares an uncomplicated recipe for a homemade tea rich in immune-boosting ingredients such as lemon, ginger, and honey. He also highlights the benefits of integrating other immunity-boosting foods into your diet, such as garlic, coconut oil, pumpkin seeds, and berries, asserting their crucial role in elevating one's well-being.
An insightful segment of the conversation is dedicated to the importance of Vitamin D supplementation for immune support, with David discussing its powerful effects and strategies for effective integration into your daily routine. The episode also addresses the influence of lifestyle choices on our ability to fight off infections, with special emphasis on the critical role of sleep in maintaining good health.
Join us in this enlightening exploration of natural and proactive ways to beat the common cold, as David imparts his wisdom and encourages listeners to take active care of their bodies. For more in-depth insights, tune in to this episode and arm yourself with the knowledge to boost your immunity and improve your quality of life."
Tuesday Mar 05, 2024
David McKeegan's Journey with Greenback Tax Services
Tuesday Mar 05, 2024
Tuesday Mar 05, 2024
March 4, 2024 - Participants include:
David McKeegan - Greenback Tax and Cleer Tax
John Richardson - Expatriationlaw
I had the opportunity to chat with David McKeegan, the founder of Greenback Tax Services. Greenback continues to be a major player in the "expat tax world" offering US tax prep services to Americans abroad throughout the world. The story of Greenback is interesting and demonstrates that U.S. taxation is what unites all Americans abroad.
What follows is the AI generated description of the interview.
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"Join us in this insightful interview with David McKeegan, founder of Greenback Tax Services, as he dives deep into the complexities of U.S. taxation for Americans living abroad. Having started his tax preparation service while living overseas himself, David explores the painful lessons and triumphs that led to the growth of this thriving business. From recognizing a widespread tax-related problem among expats in 2008, to coping with the rigours of the 2017 Tax and Jobs Act, this conversation serves as a masterclass in understanding the difficulties in navigating cross-border tax issues for Americans abroad.
Delve into the gravity of U.S. tax laws and their repercussions on American citizens striving to earn their livelihood beyond the country's shores. Discover the concept of the "Accidental American" and the ambiguity in U.S. taxation laws for residents paying taxes in countries with higher tax rates than the U.S. The interview critically examines the U.S. Government's perception of a "tax cheat", questioning if undue attention is given to expats over local taxpayers.
Engage in an intriguing discussion around the actual worth of the U.S. citizenship, especially under the weight of hefty taxes, and ponder over the idea of selling citizenship as a future solution. Get a clear picture of how the U.S. sits in the same taxation boat as countries like Eritrea and North Korea, both notorious for taxing their citizens regardless of their residency. The conversation concludes with the challenges faced by expats in planning retirement due to U.S. taxation laws and posits a need for an overhaul in the system.
The episode further evokes a strong dialogue around the potent role of the expat population in politics and taxation. Gain an understanding of the political ramifications of the U.S. citizenship taxation law and the obstacles facing expats in remote voting. In his candid conversation, David underscores the necessity of seeking advice from a tax preparer well-versed in expat taxes, and shows skepticism towards the chances of a reform in the U.S. citizenship taxation law. Immerse yourself in this enlightening discussion for real-world insights on critical expat taxation issues."
Monday Mar 04, 2024
Monday Mar 04, 2024
March 4, 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.
SEAT Working Paper Series #2023/9
Extraterritorial Taxation #9: Forcible Destruction of Citizenship
The U.S. extraterritorial tax system “abridges and affects” U.S. citizenship, leading to the forcible destruction of U.S. citizenship in violation of the 1967 U.S. Supreme Court decision Afroyim v. Rusk.
Available at: https://ssrn.com/abstract=4465596.
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AI Description:
"Join us for an insightful discussion with John Richardson, Karen Alpert, and Laura Snyder as they tackle complex and controversial issues related to citizenship taxation and the 14th Amendment. Using Laura Snyder's seat working papers as a reference, our panel converses openly about the intriguing and often misunderstood subject of forcible citizenship destruction—a topic that has been stirring debate within the community of overseas Americans.
The podcast takes off with an in-depth analysis of the 14th Amendment’s historical interpretation and its influence on citizenship and taxation. The dialogue then plows into examining its specific clauses, additionally shedding light on its impact on the fabric of modern citizenship laws. The conversation enthralls listeners with revealing discussions about the U.S. nationality-based tax system and how it inadvertently creates a hierarchy among citizens.
An essential aspect of this podcast revolves around the complex and ever-evolving terrain of U.S. Supreme Court decisions, shedding light on the significant impact they have had on the rights and lives of U.S. citizens, especially those living overseas. The conversation further probes into current laws and regulations that exert relentless pressure on U.S. citizens abroad, forcing them into a predicament of considering renunciation of their own citizenship.
The offered prognosis dives into the deep waters of the unintended consequences of extraterritorial U.S. taxation. It unravels the historical background of the issue and explores how U.S. laws, including elements within the Internal Revenue Code, have accelerated the trend of citizenship renunciations. The conversation critically reviews the issue of indirect legal mechanisms—"weaponization of citizenship" that covertly sabotage citizens' rights to keep their nationality.
The episode wraps up with a thought-provoking question—Does the current form of citizenship taxation infringe upon the 14th Amendment’s guiding principles? The dialogue succeeds in painting a broad picture of the struggles faced by U.S. citizens due to these contentious laws resulting in a unique predicament compared to citizens of other countries.
Ultimately, this episode serves as a compelling voice for the SEAT (Stop Extraterritorial American Taxation) initiative, advocating reform towards tax laws that are forcing people out of their U.S. citizenship."
Friday Feb 16, 2024
Friday Feb 16, 2024
February 16, 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.
SEAT Working Paper Series #2023/8
Extraterritorial Taxation #8: More Violations of Equal Protection
The U.S. extraterritorial tax system violates 14th Amendment equal protection not only because it is inherently suspect (as examined in Extraterritorial Taxation #7), but also because it creates a second class of citizens and is founded and perpetuated in animus.
Available at: https://ssrn.com/abstract=4465589.
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AI Description:
In this riveting podcast, John Richardson hosts a conversation with Laura Snyder and Karen Albert on citizenship taxation and its impact. The podcast sheds light on the discriminatory aspects of extraterritorial taxation, how it often results in the violation of the 14th Amendment, creating a second-class citizenship for Americans residing abroad. Discussed from historical and legal viewpoints, the episode analyzes prominent US Supreme Court decisions and their effects on citizenship taxation, providing listeners with a comprehensive understanding of this complex issue.
The conversation probes deeper through the history of constitutional law, beginning from the aftermath of the Civil War up to modern times. The hosts discuss how laws have been misused to weaponize citizenship and infringe upon the rights of American citizens despite the Supreme Court's ruling against such practices. The inherent biases of American taxation against overseas Americans and their repercussions are also critically assessed.
Legislative impacts of acts like the Foreign Account Tax Compliance Act (FATCA) and Global Intangible Low Tax Income (GILTI) on American expatriates are evaluated in great depth. They explore the controversial perspective of treating citizenship as an insurance policy and questioning the authenticity of citizens' rights. The discussed topics paint a vivid picture of the intricate nexus between citizenship and taxpayer status, potential biases in the tax system, making it a must-listen for anyone keen to understand the complexities of American citizenship and taxation.
The conversation concludes with a thought-provoking discussion on the impending need for reform in the domain of extraterritorial American taxation, urging listeners to reevaluate their understanding of this significant constitutional matter.
Wednesday Feb 14, 2024
Coach Coutts - Leave The Democracy To US!
Wednesday Feb 14, 2024
Wednesday Feb 14, 2024
February 14, 2024 - Participants Include:
David (Coach) Coutts - @RealCoachCoutts
John Richardson - @Expatriationlaw
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AI Description ...
In this riveting podcast episode, host John Richardson and Coach David Coutts frame an insightful dialogue for listeners, dissecting various lifestyle and societal topics all the way from Toronto, Canada. The focal points of their discussion encompass aspects of health, fitness, longevity, aging and a peek into David's perspectives on the political landscape in Canada.
Diving into the significance of fitness and longevity, David shares his vision of a thriving, active lifestyle even at a hundred, emphasizing the crucial role of setting meaningful, health-centered goals. One noteworthy topic broached is the concept of retirement and its misconceptions around the loss of purpose in life, touching upon the dangers of indulgence due to lack of significant activities.
Another intriguing segment of this episode delves into the perception of age within political leadership, especially in the context of ongoing debates around the age of U.S Presidential nominees. Highlighting age discrimination, David brings light to the importance of cognitive health over numerical age and the richness of accumulated experience over time.
This engaging conversation also addresses the dynamics of political tenureship, patience, legislative decision-making, and brings the democratic process under the lens. Various influential political phenomena including the dichotomy of political parties, voting disillusionment, party dominance over public representation, and critical developments in American politics are discussed.
Moreover, a sharper focus is directed towards the prevalent misunderstanding and confusion surrounding political party affiliations showcased through the recent Canadian general election. The conversation unveils the current state of Trudeau Liberals and speculates on their future prospects.
The wider disconnect between retail politicians and voters spotlights serious concerns for democracies in terms of their relevance and functionality. Despite the expressions of disenchantment, emerges a longing for a bipartisan political figure who can truly represent the people's interests.
The episode concludes by signifying the essential role of citizens in shaping the democracies, highlighting the importance of a healthier lifestyle promoting overall wellbeing. Engage with us for more captivating discussions and fresh perspectives on critical issues.
Thursday Feb 08, 2024
Thursday Feb 08, 2024
February 8, 2024 - Participants include:
Dan Lang
Jim Black
Ben Levin
John Richardson
Compassionate Justice is an educational and community initiative which focuses on the importance of transitioning from a justice system that focuses on punishment to a system that focuses on rehabilitation.
A list of upcoming events is available here:
https://esgunited.org/compassionate-justice/
An archive of past speakers in the Compassionate Justice Speakers series is here:
https://esgunited.org/compassionate-justice-past-speakers/
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The AI generated description of this podcast is:
This enlightening episode hosted by John Richardson delves into the concept of 'Compassionate Justice', its crucial importance in Canadian society, the prison systems, and introduces the founders of the 'Compassionate Justice' organization. Recorded on February 8th, 2024 in Toronto, Canada, the discussion veers away from our regular talks on immigration and tax and offers an discussion of the importance of 'Compassionate Justice' and its monumental significance.
Compassionate Justice founders - Dan Lang, Jim Black, and Ben Levin, share their experiences, motivations, and the compelling journey of the organization from its inception. Marketed by engaging narratives and research, the conversation explores the societal outlook towards crime and its legal and moral implications. It underscores the urgent necessity of an educated citizenry for understanding and responding to criminal justice.
Probing into the staggering costs of incarceration and the lack of initiatives towards rehabilitation, the episode pitches a strong case for the reformative justice system. Highlighting the injustice towards the Indigenous inmates and the unfortunate reality of post-incarceration life, the conversation unravels the need for legislative change and prison education for integration into society post-release. This insightful episode spotlights Ashley Smith's case, dissecting the tragic domino effect of legal infringements committed by parolees.
Shedding light on the dire need for funding for crucial services like Circles of Support and Accountability, the episode highlights the potential savings within the criminal justice system. It appreciates the contributions of individuals who promote Compassionate Justice initiatives, calling for continued dialogue and action towards a more compassionate and cost-effective justice system in Canada.
Tune into this episode as it climaxes with information on how you can be part of the reform. Learn about upcoming events hosted by Compassionate Justice Toronto and get involved in heralding justice system reforms.
Wednesday Jan 31, 2024
Wednesday Jan 31, 2024
January 31, 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.
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SEAT Working Paper Series #2023/7
Extraterritorial Taxation #7: Inherently Suspect
The U.S. extraterritorial tax system is subject to strict scrutiny – the highest level of equal protection scrutiny. As such, it is “inherently suspect,” in violation of 14th Amendment equal protection.
Available at: https://ssrn.com/abstract=4465558.
The following description has been generated by AI ...
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Welcome to Episode 7, a pivotal part of our comprehensive dialogue on citizenship taxation, hosted by John Richardson. In this enlightening episode, we delve deep into the law of equal protection and examine how citizenship taxation interplays with this fundamental principle.
Our conversation focuses on the role of nationality, race, and alienage in deciphering whether laws exhibit prejudice and antipathy. Laura brings forth critically acclaimed cases that throw light on why discrimination based on nationality and the country of origin is deemed unlawful without a strong justification. The episode further scrutinizes the U.S. Extraterritorial Tax System's potential bias effects depending on an individual's nationality.
Sit back and join us as we explore the law's specific terms, the pressing government interests, and the dissimilarities between a general assumption of equality and concrete reasons justifying the present situation. Listen in for a better comprehension of inherently suspect laws, including nationality-based discrimination.
This academic discussion dissects historical rulings and current opinions about citizenship-based taxation from various courts of justice, including the Supreme Court of Canada and the Federal Court of Canada. We also probe into how citizenship-based taxation transformed from a mere prerequisite for employment eligibility into a governmental tool for behavior control.
Moreover, we examine how taxation, a topic primarily associated with revenue generation, intertwines with justice, fairness, and societal organization. Finally, we touch on the controversy surrounding nationality-based taxes in the US and the financial implications of the American extraterritorial taxation policy on overseas American citizens, stimulating thoughts on a need for policy reform.
Sunday Jan 28, 2024
Sunday Jan 28, 2024
January 28, 2024 - Participants include:
Amy Purcell - @Amy_From_Sydney
John Richardson - @ExpatriationLaw
Note the following description was generated by AI - this will be interesting. AI describes this podcast as follows ...
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In this captivating episode, John Richardson engages in a revealing conversation with Amy from Sydney, a dual US-Australian citizen, about the knotty issues of taxation, citizenship, and financial concerns faced by US citizens living overseas. The dialogue dives deep into the intriguing debate about the definition of a 'US Person' and the trials implicated by dual citizenship.
The episode proceeds to demystify citizenship taxation, challenging common conceptions and shedding light on hidden terms and misconceptions. As the conversation unravels the complex realities of the US worldwide taxation system, it emphasizes the need for much-needed reforms to alleviate the challenges faced by dual citizens.
Further into the discussion, we delve into the compelling concept of a potential 'Great Australian U.S. Citizen Buyback Program,' exploring the advantages and drawbacks that come with it. Also, the revolutionary idea of shifting from citizenship-based taxation to residency-based taxation is examined as a potential ground-breaking solution. This episode encapsulates the grave dilemmas dual citizens encounter and discusses potential practical solutions.
We also touch upon political elements, like positions of different candidates on relevant topics such as residency-based taxation, and delve into controversial issues like overseas voting, and potential foreign interference in US elections. The episode explores the paradoxes and complexities faced by overseas voters who are misinformed about the US voting system whilst being subjected to its electoral laws.
The episode concludes with gripping real-life narratives and a controversial shared take on the divided perspectives on US expatriates' voting rights. Join us as we navigate the labyrinthine landscape of global citizenship, taxation, and offshore voting through engaging discussions and stimulating dialogues! Tune into this episode especially if you are a US expat wrestling with taxation and citizenship issues, or simply eager to comprehend the complexities of global citizenship and voting.
Monday Jan 15, 2024
Monday Jan 15, 2024
SEAT Working Paper Series #2023/6
January 15, 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.
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Extraterritorial Taxation #6: No Compelling Governmental Interest
This paper confronts the rationales for U.S. extraterritorial taxation with the reality of the system in place today and explains why the United States does not have a compelling interest in taxing overseas Americans in the manner it does.
Available at: https://ssrn.com/abstract=4465450.
Monday Dec 18, 2023
Monday Dec 18, 2023
December 18, 2023 - 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.
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SEAT Working Paper Series #2023/5
Extraterritorial Taxation #5: Refuting the Rationales
This paper summarizes and refutes the most commonly offered rationales for the taxation by the United States of the worldwide income of overseas Americans.
Available at: https://ssrn.com/abstract=4465327.