PREP Podcaster - ”Success Favours The PREPared Mind”

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.

SEAT Working Papers Series - Extraterritorial Taxation #7: Unlocking the Complexities and Discrimination of Citizenship Taxation Laws

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 14^th 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.

Catching Up With Amy From Sydney - Unraveling US Taxation and Voting for Expatriates

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.

SEAT Working Papers Series - Extraterritorial Taxation #6: No Compelling Governmental Interest

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.

SEAT Working Papers Series - Extraterritorial Taxation #5: Refuting the Rationales

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.

To Renounce Or NOT To Renounce: The Problem is HOW To Make The Renunciation Decision

December 13, 2023 - Participants include:

Vance - @MyLatinLife

John Richardson - @ExpatriationLaw

 

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This is the "tail end" of a podcast that I did today with Vance @MyLatinLife AKA MyLatinLife.com

It was a very interesting discussion about dual citizenship and the tremendous benefits of dual citizenship from birth (the potential avoidance of "covered expatriate" status) if one is considering renunciation of U.S. citizenship. The complete podcast will be released in January 2024 on the My Latin Life Youtube Channel.

There are many people who are tortured by the decision to renounce. Here are some of my thoughts on:

"How To Make The Renunciation Decision".

Additionally, we discussed whether other countries (including Canada) might adopt "citizenship taxation".

Although the future can never be predicted, I suspect that:

Canada will NOT follow the United States and adopt "citizenship taxation".

 

 

 

 

 

 

 

 

 

Moore v. United States -December 5, 2023 - The Argument Before The Court

Moore v. United States - December 5, 2023

Audio of the actual hearing:

This podcast is an audio of the actual argument that took place before the court. The relevant link to the Supreme Court site is:

https://www.supremecourt.gov/oral_arguments/audio/2023/22-800

Significantly a transcript of the argument is available at:

https://www.supremecourt.gov/oral_arguments/argument_transcripts/2023/22-800_9ol1.pdf

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SEAT President Dr. Laura Snyder attended the hearing. A fascinating podcast discussing her observations (right after the hearing ended) is available here.

https://prep.podbean.com/e/december-5-2023-debriefing-the-moore-case-what-happened-at-the-hearing/

SEAT along with AARO authored an amicus brief which explained the how the 965 transition tax impacted Americans abroad.

IRS Medic hosted a podcast both before, during and after the Supreme Court hearing. A link to that podcast is here:

https://twitter.com/ExpatriationLaw/status/1732254619860893932

 

 

 

December 5, 2023: Debriefing The Moore Case - A View From Inside The Courtroom - It’s All In The Snyder Report

December 5, 2023 - Participants include:

Dr. Laura Snyder - @TAPInternation

John Richardson - @Expatriationlaw

On December 5, 2023 the Supreme Court of The United States heard the Moore transition tax appeal. SEAT President Dr. Laura Snyder was present in court to hear the oral arguments and observe the Justices.

The oral argument can be heard here.

More than 50 blog posts discussing the US transition tax may be found here.

 

 

 

 

SEAT Working Papers Series - Extraterritorial Taxation #4: Why Nothing Changes

December 3, 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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Extraterritorial Taxation #4: Why Nothing Changes

This paper describes the obstacles to change of the U.S. extraterritorial tax system.

Available at: https://ssrn.com/abstract=4465208.