PREP Podcaster - ”Success Favours The PREPared Mind”

SEAT Working Papers Series -Extraterritorial Taxation #3: Education and Advocacy

November 24, 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 #3: Education and Advocacy

This paper describes the efforts of many different organizations and individuals to change to the U.S. extraterritorial tax system, to lessen its burden on overseas Americans.

Available at: https://ssrn.com/abstract=4465124.

SEAT Working Papers Series -Extraterritorial Taxation #2: How It Is Experienced

November 24, 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 #2: How It Is Experienced

This paper summarizes the findings of three recent surveys conducted to better understand how overseas Americans experience U.S. extraterritorial taxation.

Available at: https://ssrn.com/abstract=4465003

Coach Coutts - Leave The Purpose To US!

November 3, 2023 - Participants Include:

 

David (Coach) Coutts - @RealCoachCoutts

 

John Richardson - @Expatriationlaw

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One of the most extraordinary books I have ever read is Viktor Frankl's "Man's Search For Meaning". A summary of the message in the book included:

"Some see life as a never-ending quest for pleasure. Others believe life is about the accumulation of power and money. Frankl sees life as primarily a quest for meaning.

As humans we often look to the margins, those extreme situations that test the fiber of human character. Viktor Frankl survived at the ultimate margin. He concludes that the ultimate test for all of us is to find meaning in our lives. And it is within the power of everyone to find meaning, regardless of your health, wealth or circumstances – no matter how miserable or dire."

 

In a world where fewer and fewer people read, it's important to distill important messages and books into smaller digestible chunks. In this episode, Coach Coutts describes who the general message can be made more focussed, practical and helpful in the lives of everyday people.

 

 

 

 

 

SEAT Working Papers Series - Extraterritorial Taxation #1: How It Has Evolved

November 22, 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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This is the first in a series of podcasts to that are paired with various working papers and articles created by members of SEATNow.org

SEAT Working Paper Series #2023/1

Extraterritorial Taxation #1: How It Has Evolved

Since Cook v. Tait was decided in 1924 much has changed, with respect to both federal taxation and U.S. citizenship. This paper explains their parallel evolutions and why they call for Cook to be revisited.

Available at: https://ssrn.com/abstract=4464210

 

 

 

 

John Alan Pod - Episode 214: Taxation And Americans Abroad

September 21, 2023 - Participants Include:

John Alan - @JohnAlanPod

Keith Redmond - @Keith__Redmond

Anthony Parent - @IRS_Medic

John Richardson - @Expatriationlaw

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Note this podcast is based on an interview with John Alan. The podcast was initially posted on his site at:

https://johnalanpod.podbean.com/e/taxes-are-no-easy-thing-for-american-expats-and-accidental-americans-episode-214/

It is reposted here with John Alan's permission.

 

 

 

Responding To The Bittner FBAR Decision - The IRS ”Resets” The Penalty Principles

August 15, 2023 - Participants include:

 

Virginia La Torre Jeker - @VLJeker

John Richardson - @Expatriationlaw

 

Out with the "mitigation provisions" and a reminder that penalties for the failure to keep records can result in a separate penalty!

On August 10, 2023 Virgina La Torre Jeker published a post about the great FBAR penalty reset - the IRS response to the Bittner decision.

It's all about the new IRS FBAR Guidance Memorandum which took effect on July 6, 2023.

You can read it here:

https://www.irs.gov/pub/foia/ig/sbse/sbse-04-0723-0034-redacted.pdf

Clearly this is NOT "good news" for taxpayers (or should it say individuals with bank and financial accounts outside the United States).

 

 

 

 

 

A US Social Security Primer With Katrina Haynes of HaynesHelp

August 7, 2023 - Participants include:

 

Katrina Haynes - Haynes Help

 

John Richardson - @Expatriationlaw

 

Thanking Katrina Haynes of HaynesHelp.com for a great discussion reviewing:

- entitlement to U.S. Social Security generally

- the two things that "totalization agreements" achieve U.S. citizens who move out of the United States

- Renunciation of citizenship, Green Card abandonment and entitlement to U.S. Social Security

- taxation of Social Security benefits as a U.S. citizen or as a nonresident alien

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For a complimentary webinar with Katrina on FBAR and Form 8938 for Americans abroad click here.

 

 

Why The 3.8% NIIT (”Net Investment Income Tax”) Is Especially Unjust For Americans Abroad

August 4, 2023 - Participants Include:

 

Virginia La Torre Jeker - @VLJeker

 

John Richardson - @Expatriationlaw

 

On July 27, 2023 Virginia La Torre Jeker published a blog post about the 3.8% NIIT ("Net Investment Income Tax"). The post is an excellent discussion of the "Net Investment Income Tax" generally and how it impacts Americans abroad specifically.

As a general principle the NIIT unfairly discriminates agains Americans abroad in (at least) the following ways:

1. The NIIT applies to those who use "married filing separately" category at a lower threshold ($125,000) than to those who use "married filing jointly" ($250,000). Because a higher percentage of Americans living outside the USA use the "married filing separately" category, the NIIT applies to a higher percentage of Americans abroad.

2. Because the US foreign tax credit rules do not allow foreign tax paid on investment income to be used as a foreign tax credit, the NIIT is virtually guaranteed to cause double taxation for Americans abroad. It is in effect a 3.8% US surcharge on non-U.S. investment income.

3. The NIIT applies to both PFIC (non-US mutual fund income) and CFC (Subpart F income) causing additional hardship for Americans abroad.

4. While exempting income from U.S. 401K (and similar U.S. income) from the NIIT, but applying the NIIT to non-U.S. tax deferred accounts (example Canadian RRSP) it further penalizes Americans abroad.

Incidentally, the purpose of the NIIT was to fund healthcare for U.S. residents. This healthcare is NOT available to Americans abroad.

Therefore, the NIIT is another particularly egregious example of U.S. citizenship-based taxation.

 

 

 

 

 

 

Meeting Anthony Parent: The Man Behind IRS Medic

July 25, 2023 - Participants include:

 

John Richardson - @Expatriationlaw

 

Anthony Parent - @IRS_Medic

 

Anthony Parent of IRS Medic has created hundreds of video podcasts and has interviewed a wide range of guests.

Interestingly few people know Anthony:

 

"The Man Behind The Medic"

Here is your chance to meet Anthony ...

 

 

 

 

 

 

Should Digital Nomads Living Outside The USA Keep All Their Financial Accounts In The USA?

May 27, 2023 - Participants include:

 

Vance - @MyLatinLife

 

John Richardson - @Expatriationlaw

 

A supplementary discussion with Vance of MyLatinLife.com. This is a wide ranging discussion of the practicalities of living outside the United States.

This podcast also appears on Youtube at:

https://www.youtube.com/watch?v=K3Q1BIc2FzI

 

Borrowing from the Youtube description:

 

In this BONUS episode John and Vance discuss personal finances, banking, real estate, taxes, and reporting requirements for US citizens abroad. 🌴 Timestamps: 0:00 Intro 4:30 Reporting Requirements vs Taxation 7:30 Personal Finance for US Citizens 10:30 Issues for Canadian American Dual Citizens 16:40 Dual Tax Residency & Territorial Tax Countries 23:00 Renouncing US citizenship 28:30 Corporations and Trusts 33:30 Tax Advice for Expats 40:30 Retirement Planning for Americans Abroad 48:00 Social Security Taxes and Pension Benefits 55:00 Advice to 20 year olds 1:00:30 Banking in the USA while Outside the USA 1:10:00 Foreign Earned Income Exclusion (FEIE) 🌴 Follow John Richardson: Twitter: https://twitter.com/ExpatriationLaw Website: http://citizenshipsolutions.ca 🌴 Follow My Latin Life: City Guides: https://mylatinlife.com/city-guides/ FREE Telegram Group: https://t.me/+u18h0doDhxRiY2Fh Twitter: https://twitter.com/MyLatinLife Set up a Base in LatAm: https://calendly.com/MyLatinLife