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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 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
Monday May 29, 2023
Monday May 29, 2023
May 27, 2023 - Participants Include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
The decision may be accessed is here.
Last week a Belgian tribunal charged with investigating and determining violations of the GDPR "General Data Protection Regulation" ruled on a complaint brought two an "Accidental American" in Belgium and the Association of Belgium Accidental Americans.
The tribunal ruled that to send information to the IRS under the FATCA IGA did indeed violate the GDPR. The decision can (and certainly will) be appealed. The decision is long (77 pages), complicated and identified a number of different reasons why the FATCA IGAs conflicted with the GDPR. This is hardly surprising given the the whole purpose of the FATCA (expressed in the FATCA IGAs) is is to deprive US citizens of any and all rights with respect to their banking information.
The Belgium decision has now created a situation where as long as there are U.S. "reportable accounts" in Belgium the transference of FATCA data to the IRS will result in either:
- a violation of the FATCA IGAs (and therefore U.S. law); or
- a violation of the GDPR (and therefore Belgium law).
It would seem that the only way to avoid violating the law would be if there were NO FATCA data to report. This can be achieved by and only by either
- terminating the banking accounts of all U.S. citizens in Belgium; or
- relying on the provision in the IGA that does not require the reporting of "Depository" (not custodial) accounts with a balance of less than $50,000. (See page 8 of the U.S. Belgium FATCA IGA.)
"A. Accounts Not Required to Be Reviewed, Identified, or Reported. Unless the Reporting Belgian Financial Institution elects otherwise, either with respect to all New Individual Accounts or, separately, with respect to any clearly identified group of such accounts, where the implementing rules in Belgium provide for such an election, the following New Individual Accounts are not required to be reviewed, identified, or reported as U.S. Reportable Accounts: 1. A Depository Account unless the account balance exceeds $50,000 at the end of any calendar year or other appropriate reporting period."
https://home.treasury.gov/system/files/131/FATCA-Agreement-Belgium-4-23-2014.pdf
In any case, the real issue is whether Belgium is to be run by the United States (as a territory or vassal state) or whether Belgium is a "sovereign country".
It will be interesting to see how this develops.
Thursday May 04, 2023
Thursday May 04, 2023
Appeal - May 3, 2023 - District Court Of Appeals
As many of you know the Association of Accidental Americans sued the U.S. State Department over the issue of limiting renunciation appointments during the Covid19 pandemic.
This is a recording of the appeal heard on May 3, 2023.
Friday Apr 28, 2023
Friday Apr 28, 2023
April 28, 2023 - Participants Include:
Personal Trainer David Coutts - @RealCoachCoutts
John Richardson - @Expatriationlaw
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Note: Check back for the link to the Video version!
Thursday Apr 20, 2023
Thursday Apr 20, 2023
April 17, 2023 - Participants include:
Janine Seymour - @MiAzhikwan
John Richardson - @Expatriationlaw
It’s almost a half century since a Charter of Rights became part of Canada’s constitution. Has the Charter fulfilled its promise?
Many opinions are reflected as replies to Justin Trudeau’s “Happy Birthday Charter Tweet”.
https://twitter.com/JustinTrudeau/status/1648033598023299074