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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
Tuesday Sep 26, 2023
Tuesday Sep 26, 2023
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:
It is reposted here with John Alan's permission.
Tuesday Aug 15, 2023
Tuesday Aug 15, 2023
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).
Monday Aug 07, 2023
Monday Aug 07, 2023
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.
Friday Aug 04, 2023
Friday Aug 04, 2023
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.
Wednesday Jul 26, 2023
Wednesday Jul 26, 2023
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 ...
Wednesday Jun 28, 2023
Wednesday Jun 28, 2023
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
Tuesday Jun 27, 2023
Tuesday Jun 27, 2023
June 27, 2023 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
As more and more people renounce U.S. citizenship or surrender their Green Cards the will take steps to avoid being a "Covered Expatriate".
A "Covered Expatriate" is an individual (subject to few exceptions) who meets any one of the following three tests:
- net worth in excess of 2 million USD
- U.S. tax liability exceeding an average of $190,000 USD in the five years prior to renunciation
- failure to certify U.S. tax compliance for the five years prior to renunciation.
The consequences of being a "Covered Expatriate" are two-fold:
1. Being subject to the 877A Expatriation Tax
2. Gifts/bequests made to "U.S. Persons" being subjected to a 40% tax (payable by the recipient of the gift) as per S. 2801 of the Internal Revenue Code.
It's important that the recipient of the gift be able to prove that the gift/bequest was NOT received by a "Covered Expatriate".
In this podcast we discuss common sense steps that can (and should) be taken to meet the burden of proof of showing that the gift/bequest was NOT received from a "Covered Expatriate".
Wednesday Jun 07, 2023
Wednesday Jun 07, 2023
Wednesday Jun 07, 2023
Wednesday Jun 07, 2023
May 27, 2023 - Participants include:
Vance - @MyLatinLife
John Richardson - @Expatriationlaw
There are many people who see the value in acquiring second citizenships or second residencies. There is a range of opportunities available that include: citizenship, permanent residence status, various visas and most recently the "digitial nomad visa". Each of these options has different costs and opportunities.
These opportunities exist all around the world. In this podcast you will be introduced to Vance of "My Latin Life" fame who has a special affection for the opportunities available in Latin America.
Vance describes a process for people who see the value in:
1. A second citizenship or residency; in
2. A location with a territorial tax system.
In this episode you will learn why. For more about "My Latin Life", visit:
Wednesday Jun 07, 2023
Wednesday Jun 07, 2023
June 7, 2023 - Participants include:
David AKA "Coach" Coutts - @RealCoachCoutts
John Richardson - @ExpatriationLaw