PREP Podcaster - ”Success Favours The PREPared Mind”

SEAT Working Paper Series - Extraterritorial Taxation #12: It's Not About Paying Taxes

March 26, 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.

Extraterritorial Taxation #12: It’s Not About Paying Taxes

Objections to the U.S. extraterritorial tax system are not about paying taxes – most owe no U.S. tax – but about a highly complex and penalizing system that prevents overseas Americans from living normal lives and subjects them to high levels of risk and stress.

Available at: https://ssrn.com/abstract=4466128.

 

 

Insights into the Intertwining of Politics and the Law in Ontario's Justice System

March 12, 2024 - Participants Include:

 

Doug Judson - Judson Howie

Norman Douglass - Retired Ontario Judge

Dan Lang - Compassionate Justice Toronto

Jim Black - Compassionate Justice Toronto

Ben Levin - Compassionaste Justice Toronto

John Richardson - Compassionate Justice Toronto

 

On February 23, 2024 the Toronto Star reported that Ontario Premier Doug Ford announced his intention to appoint "like minded judges" to Ontario's Provincial Courts. His statement (widely reported by the media) was controversial. At a minimum it suggested an intention to politicize the judicial process - eroding the independence of the judicial system.

 

Jeff Gray writing for the Globe and Mail in February 23, 2024:

 

"Ontario Premier Doug Ford says he has the right to choose “like-minded” conservative judges and defended his installation of two former senior political aides on the government’s judicial appointments committee – the latest in a series of moves critics say is politicizing the province’s courts.

Lawyers groups and opposition politicians raised alarms about the Premier’s comments on Friday, saying they amount to a rejection of judicial independence, undermine public confidence in the courts and set a course toward a U.S.-style partisan justice system.

Mr. Ford was unrepentant when asked about a Toronto Star story that his government had put two of his former senior political aides on the province’s Judicial Appointments Advisory Committee, which vets and shortlists candidates for Attorney-General Doug Downey to name to the Ontario Court of Justice."

 

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AI Description ...

"In this compelling podcast episode, a seasoned panel of legal experts, including retired judges and practicing lawyers, delves into crucial topics like judicial appointments, the independence of the judiciary in Ontario, and potential political influences on legal decisions. The conversation sheds light on the controversial prospect of appointing "like-minded judges", a statement attributed to Ontario's Premier Doug Ford.

An interesting narrative emerges as Doug Judson, Chair of the Federation of Ontario Law Associations, retired Judge Norman Douglass and other panelists such as Dan Lang, Jim Black, and Ben Levin intricately break down the recent changes to the judicial selection process and its potential implications on the justice system. The dialogue goes further to decipher the media's impact on public perception of crime, justice, and law enforcement, probing the dangerous possibilities of a distorted perspective.

Highlighting the utmost importance of an independent judiciary in a healthy democracy, this podcast delves into the room for political interference, the broad-brushing of the judiciary, and the necessity for balance across various sectors within the legal framework. The conversation wraps up exploring aspects of resource allocation, the viability of drug treatment courts over creating more jails, the call for more diversity in the bench, and an overall comprehensive outlook of a just criminal justice system.

Join this enlightening conversation, presenting an in-depth analysis of the justice system, the indispensable role of public discourse, and the future of the judiciary in Ontario."

SEAT Working Paper Series - Extraterritorial Taxation #11: Deference or Constitutionalization?

March 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.

 

Extraterritorial Taxation #11: Deference or Constitutionalization?

Instead of practicing deference, federal courts must subject tax legislation to the same constitutional review to which they subject other legislation.

Available at: https://ssrn.com/abstract=4465622.

AI Version:

 

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"In this informative episode, host John Richardson delves into the complex narrative surrounding taxation and constitution rights, intricately dissecting the question - Should U.S. tax law be constitutionally reviewed? This leads him and his guest experts into the nuanced layers of "Extraterritorial Taxation: Deference or Constitutionalization?", the provocative topic of Seat Working Paper 11.

The experts, Laura Snyder hailing from Paris and Karen Alpert from Australia, dissect the underlying purpose of the working paper. They engage in a deep discussion about the roles of the Supreme Court and Congress in shaping tax laws, providing unprecedented insights into the topic. They pose acute queries regarding the possible power dynamics and repercussions that could result if tax law creation remains unchecked and outside constitutional review.

Taking the discussion a step further, they link the discussion with the plight of American expats. They explore the profound implications regulations have on fundamental rights and use the U.S tax code as an example. The debate highlights the fallback of unlimited tax powers and reiterates the importance of forming equitable tax policies.

Join Richardson and his esteemed guests as they unravel complicated discussion on the potential influence taxation has on societal behavior, ethical dilemmas concerning human rights and tax laws, and the critical role of constitutional review in striking a balance between the state's fiscal needs and citizens' fundamental rights.

Listeners can expect an enlightening dialogue that simplifies the labyrinth of tax laws and provides valuable insights for both legal experts and everyday citizens. Tune in for the captivating dialogue on complexities of taxation and the potential constitutionalization of U.S. tax laws."

SEAT Working Paper Series - Extraterritorial Taxation #10: Violating Human Rights

March 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.

 

Extraterritorial Taxation #10: Violating Human Rights

The U.S. extraterritorial tax system violates multiple international human rights instruments that the United States has signed, or signed and ratified.

Available at: https://ssrn.com/abstract=4465610.

AI Version:

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"In this thought-provoking podcast episode, host John Richardson, along with experts Karen Alpert from Australia and Laura Snyder in Paris, delve deep into the complex subject of extraterritorial taxation in the United States and its potential interference with fundamental human rights. Providing comprehensive insights and discussions, we explore the divergences between the American Constitution and international human rights, especially impacting US citizens living overseas.

Our discussion highlights the vital interplays of the American Constitution, the role of the legislature, the judiciary, and the controversial effects it imposes upon its citizens' rights and obligations, both domestically and abroad. We focus on the extensive impacts of the U.S. extraterritorial tax system on Americans living overseas, notably the discriminatory effects and constraints on entrepreneurial and employment opportunities.

Framing a perspective on the contentious claim that U.S. citizenship can be seen as a 'fiscal prison' in the 21st century, this episode stirs up thought and debates about the free right to live and work as a U.S. citizen living abroad.

In the latter part of the podcast, this audacious discussion extends towards the implications of the U.S.'s taxation system on self-determination and economies of other nations. We ponder over the proposition of U.S. citizenship taxation as a form of economic warfare and the subsequent potential human rights violations.

Join us in this enlightening discussion to understand more about the root causes and potential solutions to these complex tax situations and play your part in ceasing extraterritorial American taxation. Explore more only at SEATNow.org."

Insights on Boosting Immunity to fight the common cold with Health Coach David Coutts

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."

David McKeegan's Journey with Greenback Tax Services

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."

SEAT Working Papers Series - Extraterritorial Taxation #9: Forcible Destruction Of Citizenship

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."

SEAT Working Papers Series - Extraterritorial Taxation #8: More Violations of Equal Protection

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 14^th 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.

Coach Coutts - Leave The Democracy To US!

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.

Canada's Justice System: A Deep Dive With The Founders of Compassionate Justice Canada

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.