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 ...
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Fatca Podcasts
In our Spotlight on Financial Services Tax series, Tax Partner - Peter Maybrey and Middle East Information Reporting Leader - Bilal Abba, look at the key issues Middle East based businesses need to be aware of and how they apply to the financial services sector.
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Fee, Fines, and Forced Farewells: The Hidden Toll on Americans Abroad
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13:39
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13:39January 2, 2026 - AI generated podcast from upcoming post written by John Richardson at The Isaac Brock Society. "In this episode of The Deep Dive we unpack the three-year delay in reducing the Certificate of Loss of Nationality (CLN) fee and what that delay reveals about the U.S. government's treatment of Americans living abroad. Using public comm…
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Safety vs. Subsidy: FAA’s 90-Day Safety Mandate For Airplances vs. A Proposed Fee Cut To Issue A Certificate Of Loss Of Nationality
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13:19
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13:19December 29, 2025 - AI Generated This is an AI generated podcast which describes the Rule Making Notice which appeared in the Federal Register on October 2, 2023. This notice describes the Rule Making undertaken by the State Department to reduce the fee to process a Certificate of Loss of Nationality from $2350 to $450 (where it was in 2014). A lin…
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Moreno Bill Fallout: Dual Citizens Could Lose U.S. Status and Face Exit Taxes
29:58
29:58
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29:58December 8, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw "Hosts John Richardson and Virginia La Torre Jeker unpack Senator Moreno's proposed bill to eliminate dual citizenship and the practical effects it could have if enacted. They explain the tax risks, including the exit tax and "covered expa…
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Uprooting Dual Citizens: The Exclusive Citizenship Act Explained
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33:08
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33:08December 3, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw This podcast is based on Virginia's Forbes article - "Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship" - which appeared on December 3, 2025. AI generated description: "Host Virginia La Torre Jeker discuss the "Exclusive…
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Exclusive Citizenship Act 2025: Is Dual Citizenship Over?
1:06:21
1:06:21
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1:06:21December 3, 2025 - Participants include: Parviz Malakouti - @ParvizMalakouti Brent Vanderbrook - @Vanderbrook John Richardson - @ExpatriationLaw This podcast of an X.com "Space" that took place on December 3, 2025. Here it is: https://x.com/ParvizMalakouti/status/1995905374034297232 "Citizenship and Immigration Attorney Parviz Malakouti breaks down…
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FBAR at 55: How a Cold War Rule Became an Expat Crisis
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12:28
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12:28November 20, 2025 - An AI generated podcast from a John Richardson presentation with IRS Medic. AI generated summary: "This episode unpacks FBAR—from its 1970 origins under the Bank Secrecy Act to today’s wide reporting net that catches signing authority, beneficial ownership, and many routine foreign accounts. We explain the filing threshold, how …
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Parviz Malakouti - Space 50 - November 13, 2025 - Afroyim v. Rusk
1:47:08
1:47:08
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1:47:08November 13, 2025 - Participants include: Parviz Malakouti - @ParvizMalakouti Brent Vanderbook - @Vanderbrook John Richardson - @ExpatriationLaw Information, reason and the outline of the "Space" is here: https://x.com/ParvizMalakouti/status/1986483363931431382By prep
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Citizenship Apartheid: How Birthright Builds a Global Caste
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11:46
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11:46November 11, 2025 Citizenship Apartheid - Paper by Professor Dimitry Kochenov https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4680018 This podcast is based on Professor Kochenov's thought provoking paper. AI description: "In this episode we unpack a provocative argument: modern citizenship functions as a form of global apartheid, sorting people…
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Buffett, 95, Converts A Shares into 2.7M B Shares — Huge Charity Gift
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12:14
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12:14November 10, 2025 - Warren Buffet letter to Berkshire shareholders. A "treasure trove"of advice ... https://www.berkshirehathaway.com/news/nov1025.pdf Here is the AI description: "In his November 10, 2025 Thanksgiving message, Warren Buffett, 95, disclosed converting 1,800 A shares into 2.7 million B shares and immediately earmarking them for four …
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When Marriage Meets U.S. Citizenship Tax: The Community Property Trap for Citizens Abroad
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26:46
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26:46November 9, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw Prologue: Virginia recently published a post discussing the issues generated by a U.S. citizen married to a nonresident alien with the couple living in a non-US "community property jurisdiction". You are invited to read the post here: http…
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Born Abroad, American by Law: Should You Register Your Child?
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39:08
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39:08November 8, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw Prologue: 8 U.S. Code § 1401 - Nationals and citizens of United States at birth "The following shall be nationals and citizens of the United States at birth: (g) a person born outside the geographical limits of the United States and its ou…
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Unmasking the Saving Clause: Why Americans Abroad Face Guaranteed Double Taxation
1:16:12
1:16:12
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1:16:12October 8, 2025 - Participants include: Tim Symthe - @TpSmyth01 David Bindel - @DavidBindelTx Dr. Suzanne DeTreville - @SDeTreville John Richardson - @ExpatriationLaw "This episode examines the U.S. tax treaty "saving clause," which lets the United States deny treaty residency tiebreaker benefits to U.S. citizens and effectively causes double taxat…
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Renounce or Retain: The High‑Stakes Tax Choice for Americans Abroad
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14:10
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14:10October 1, 2025 - AI Generated Podcast ... John Richardson - @Expatriationaw Presentation "This episode explains the tough decision facing Americans living overseas: keep U.S. citizenship and face lifetime worldwide taxation and compliance, or formally renounce and risk immediate tax, estate, and immigration consequences. We break down the biggest …
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Can the IRS Fine You Without a Jury? The Sagoo FBAR Showdown
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17:28
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17:28September 24, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw The law of FBAR is found in Title 31 of the Bank Secrecy Act. Specifically 5314 is thought to define the FBAR obligation and 5321 prescribes civil penalties. The actual requirements are found in Regulation 1010.350. As a result of the re…
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When Borders Matter: How U.S. Estate & Gift Taxes Hit Global Families
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15:44
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15:44AI version of pdf presentation: John Richardson ____________________________________________ Warning!! This is a very complex area. I am not entirely happy with how AI generated this podcast. It's main. purpose is to highlight the importance of understanding your situation and getting proper advice!! AI generated description: This episode is a clea…
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Taxed From Afar: The Hidden Cost of U.S. Citizenship
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54:48
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54:48September 6, 2025 - Participants include: Latife Hayson - Youtube.com/@LatifeHayson Dr. Karen Alpert - @FixTheTaxTreaty Dr. Laura Snyder - @TAPInternation John Richardson - @ExpatriationLaw In July of 2025 Latife Hayson produced a lengthy video exploring the taxation of Americans abroad. Latife Hayson and a SEAT members Karen Alpert, Laura Snyder a…
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Stay Strong to Be Strong: A 40-Year-Old’s Guide to Lasting Fitness
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26:58
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26:58September 5, 2025 - Participants include: David Coutts - @RealCoachCoutts John Richardson - @ExpatriationLaw AI generated description: "John Richardson talks with Coach Coutts about turning 40, why strength matters for longevity, and how anyone—no matter their starting point—can begin improving fitness and mobility. They cover practical tips like w…
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When Birthright Becomes Burden: Living American, Abroad and Taxed
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16:02
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16:02In February of 2015 I (John Richardson) did a presentation at a tax conference called: "Sacred Trust: Counselling Clients Through The Trauma Of U.S. Citizenship Abroad in a "FATCAesque World" I was curious to see what kind of podcast would be generated from the presentation. What follows is the result. AI Generated: "Imagine discovering that your U…
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Beyond Borders: Rethinking Citizenship Taxation In A World Of Global Mobility
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23:13
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23:13August 15, 2025 - AI Generated Podcast ... This podcast is a discussion of a recent 2025 paper by Professors Ruth Mason of the University of Virginia and Tsilly Dagan of the University of Oxford title: Reconsidering Citizenship Taxation Both the paper and the AI generated podcast based on the paper are interesting. The paper discusses citizenship t…
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The Hidden Risks of Multiple Citizenship: Exploring The Challenges And Necessity Of Renunciation
1:21:09
1:21:09
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1:21:09August 8, 2025 - Speakers Include: Alex Ugorji - @AlexUgorji David Bindel - @DavidBindelTx Mat Farel - @MatFarel Parviz Malakouti - @ParvizMalakouti John Richardson - @ExpatriationLaw AI Description: "Join Citizenship and Immigration Attorney Parviz Malakouti in a deep dive into the complexities surrounding citizenship renunciation. In this insight…
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Unraveling the Complexities of Tax Fraud and Denaturalization
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45:15
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45:15August 5, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw Prologue: On June 11, 2025, the Department of Justice issued a memo indicating that it planned to prioritize the denaturalization of certain U.S. citizens. In early August of 2025, media reports began circulating describing a naturalized cit…
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Congressman Hurd - H.R. 4501 - Exempt U.S. Citizen Pope Leo From U.S. taxation
1:23:41
1:23:41
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1:23:41July 30, 2025 - Speakers Include: Dr. Laura Snyder - @TAPInternation Parviz Malakouti - @ParvizMalakouti BitCoin Backpacker - @BackPacker_BTC John Richardson - @ExpatriationLaw On July 17, 2025 Representative Hurd of Colorado introduced Bill H.R. 4501. The purposes of the bill would include the exemption of U.S. citizen Pope Leo from taxation under…
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Dan Duggan and Roger Ver Extraditions: When Does A U.S. Citizen Lose Citizenship?
2:44:20
2:44:20
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2:44:20July 24, 2025 This is a recording of a discussion an “ X.com Space” hosted by U.S. immigration Parviz Malakouti. I (John Richardson) contributed to the discussion. When exactly does a U.S. citizen relinquish U.S. citizenship? X.com Handles: Parviz Malakouti - @ParvizMalakouti John Richardson - @ExpatriationLaw…
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Renunciation vs. Relinquishment Of U.S. Citizenship - Why The Difference Can Matter
2:25:36
2:25:36
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2:25:36July 21, 2025 This is a recording of a discussion an “ X.com Space” hosted by U.S. immigration Parviz Malakouti. I (John Richardson) contributed to the discussion. X.com Handles Parviz Malakouti - @ParvizMalakouti John Richardson - @ExpatriationLawBy prep
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Unraveling the Hidden "Saving Clause" in Global Tax Treaties
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20:33
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20:33This AI generated podcast is based on a paper written by Professor Leopoldo Parada. Although a “saving clause” has been a feature of U.S. tax treaties for years, the OECD Model Treaty did not have a “saving clause” before 2017. Interestingly, the OECD commentary suggests that the purpose of the “saving clause” was to allow for the taxation of contr…
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Unraveling the Green Card's Hidden Tax Obligations Triggered By Abandoning The Green Card
17:56
17:56
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17:56This AI generated podcast is from a John Richardson presentation about “Green Card Abandonment”. The presentation - “Understanding The Green Card (if you can)” - took place on May 1, 2024 on the IRS Medic Podcast. AI Description: "Think you know everything about a green card? Think again. In this episode, we explore the less-discussed side of holdi…
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How U.S. Citizens Abroad Are Subject To A More Punitive Tax System Than Are U.S. Residents
19:53
19:53
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19:53This AI generated podcast is based on an article written by John Richardson on March 12, 2019 at Citizenship Solutions. It was republished on March 13, 2019 post at Tax Connections. The Tax Connections version received a lot of comments. You can find the article on Tax Connections here. The comments are extremely interesting. What follows is an AI …
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A Simple Regulatory Fix For Citizenship Taxation
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26:44
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26:44In November of 2020, SEAT members John Richardson, Karen Alpert and Laura Snyder published “A Simple Regulatory Fix For Citizenship Taxation”. This was the first article (and possibly suggestion) that the problems of Americans abroad could be solved through regulation. We participated in a video podcast with Robert Goulder at Tax Notes. Here is the…
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If A U.S. Citizen Is Stripped Of His Citizenship, Will He Be Subject To the Exit Tax Regime?
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23:56
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23:56July 12, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw _________________________________________________ Introduction: The Trump administration has served notice of its focus on stripping certain U.S. citizens of their citizenship. This comes on the heels of increased aggression toward Green Card…
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Why U.S. Citizens Abroad Should Be Exempt From Reporting Their Local Accounts To FINCEN (Financial Crimes)
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12:52
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12:52July 11, 2025 - "Why non-resident U.S. citizens should be exempted from FBAR" Introduction: This is an AI generated podcast which is based on a submission I made in April of 2024 explaining “Why non-resident citizens should be exempted from the FBAR” What follows is the AI description of the podcast …. AI Description: "In this episode of The Deep D…
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Unveiling the Secrets of Homeless Income: How Multinationals Exploit Global Tax Treaties
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23:46
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23:46This is an AI generated podcast of a 2014 paper written by Professor Bret Wells and Cym Lowell titled: “Income Tax Treaty Policy in the 21st Century: Residence vs. Source” Why this is important: The Trump administration recently proposed (as part of the “OBBB”) a provision that would impose tax penalties on residents of countries that had DSTs (“Di…
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"Citizenship and Taxation: The Twin Destinies Shaping Global Mobility"
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13:00
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13:00June 12, 2025 - Participant includes: John Richardson - @ExpatriationLaw On June 12, 2025 SEAT members Laura Snyder and John Richardson separately gave presentations at the Migration Conference held at the University of Greenwich in London, UK. A complete description may be found on the SEAT site here. A brief outline of John's presentation (and th…
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The Immigration Dilemma: A Tale of Two Stories
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16:19
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16:19June 12, 2025 - Participant includes: Dr. Laura Snyder - @TAPInternation On June 12, 2025 SEAT members Laura Snyder and John Richardson separately gave presentations at the Migration Conference held at the University of Greenwich in London, UK. A complete description may be found on the SEAT site here. This podcast is a recording of Laura’s present…
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Navigating FATCA: The Accidental American's Struggle with Captain Ronald Aries
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31:04
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31:04May 30, 2025 - Participants include: Ronald Aries - @Ronald77171496 John Richardson - @ExpatriationLaw Introduction: Someday FATCA historians will seek to understand the impact of FATCA and U.S. citizenship taxation on individuals born in the USA, with no memory of having lived in the USA, who moved from the USA at a very early age and grew up as r…
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The Proposed Remittance Tax: Who's In? Who's Out?
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34:05
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34:05May 18, 2025 - Participants include: Dr. Laura Snyder - @TAPInternation John Richardson - @ExpatriationLaw Introduction: Part of the "Big Beautiful Bill" introduced by the Trump administration includes a 5% tax on "remittance transfers". Contrary to the publicity, this provision is NOT restricted to "illegal aliens" and is NOT restricted to remitta…
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Podcast 2: The First American Pope and the FBAR Predicament
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24:45
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24:45May 16, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @Expatriationlaw On May 4, 2025 Virginia and I did a podcast about the possibility of a U.S. citizen being appointed Pope. You can access that first podcast here: https://prep.podbean.com/e/a-us-citizen-as-pope-exploring-tax-implications-and-controversies/ Thi…
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Toward An Argument That US Citizenship Taxation Violates International Law
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8:10
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8:10May 4, 2025 - An AI conversion of a written blog post into a podcast ... Here is the original blog post from April of 2025: https://citizenshipsolutions.ca/2025/04/20/toward-an-argument-that-us-citizenship-taxation-violates-international-law/ AI - Generated podcast: This podcast episode delves into the complexities of FATCA litigation and U.S. citi…
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A U.S. Citizen as Pope? Exploring Tax Implications and Controversies
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28:12
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28:12May 4, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw Introduction: The idea for this podcast came from a New York Times article discussing the possibility of a U.S. citizen becoming the next Pope. It is likely that the Pope would have the authority - as per the FBAR Regulation: "to control the di…
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Space 26 - April 14, 2025 - The Evolution of @CitizenshipTax - From 1979 - 2025
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2:01:43
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2:01:43April 14, 2025 - Participants include: Dr. Suzanne de Treville - @SdeTreville Tim Smyth - @TpSmyth01 Brad - @InvertedFragility Brent Vanderbrook - @Vanderbrook Jacob - @Giorniofr John Richardson - @ExpatriationLaw Note: This podcast is a recording of an "X Spaces" discussion. The actual audio does not start until approximately the two minute mark. …
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Space 25 - April 12, 2025: The 1980 Carter Report On Citizenship Taxation: Nothing Has Changed In 45 Years
2:40:22
2:40:22
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2:40:22April 12, 2025 - Participants include: Dr. Suzanne de Treville - @SdeTreville Tim Smyth - @TpSmyth01 Brad - @InvertedFragility Brent Vanderbrook - @Vanderbrook John Richardson - @ExpatriationLaw Note: This podcast is a recording of an "X Spaces" discussion. The actual audio does not start until approximately the two minute mark. ___________________…
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Breaking Down Barriers: Enabling US ETF Sales in the UK And A Call To Action
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4:15March 19, 2025 - Participants include: Rebecca Lammers - @AbroadRebecca John Richardson - @ExpatriationLaw Context: This podcast is suppleented by Rebecca's blog post here: https://medium.com/@tapinternational/dear-fca-please-change-the-regulations-so-us-citizens-in-the-uk-can-invest-in-us-etfs-61df27e40c76 AI Version: "Join John Richardson and Reb…
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Decoding PFIC Form 8621: The IRS Response and Its Impact on Americans Abroad
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50:45March 19, 2025 - Participants include: Rebecca Lammers - @AbroadRebecca John Richardson - @ExpatriationLaw Context: On March 1, 2025 the IRS released its response to public comments about PFIC Form 8621. The request for comments provided an opportunity for Americans abroad - a group disproportionately impacted by the PFIC problem - to report its di…
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Unveiling Tax Reform: A Bright Future for Americans Abroad?
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26:37March 11, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw ______________________________________ In this podcast we discuss Virginia's March 11, 2025 post: https://us-tax.org/2025/03/11/leaked-memo-includes-major-tax-reform-and-impacts-u-s-persons-abroad/ AI Description: "In this enlightening episo…
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Understanding the Complexities of Covered Expatriates And The U.S. 2801 Covered Gift Tax Provisions
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41:39
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41:39January 25, 2025 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw Background: 1. Here is IRC S. 2810 2. Here are the 2801 Regulations effective January 1, 2025 AI Decription: "In this insightful episode, John Richardson hosts U.S. tax lawyer Virginia La Torre Jeker to unravel the complexities of U.S. tax…
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The Year of 2024 in Review: "It Takes A Village" - Americans Abroad and Taxation Issues
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40:41December 22, 2024 - Participants include: Laura Snyder - @TAPInternation Keith Redmond - @Keith__Redmond John Richardson - @ExpatriationLaw AI Description: "Join hosts John Richardson, Keith Redman, and Laura Snyder as they delve into the intricacies of citizenship-based taxation and its impact on Americans living overseas. Broadcasting from Toront…
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Groundbreaking Repeal: U.S. Senate Abolishes WEP for U.S. Citizens Living Abroad
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21:44
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21:44December 21, 2024 - Participants include: Doris Speer - @AARO President John Richardson - @ExpatriationLaw On December 21, 2024 the U.S. Senate passed H.R. 82 - The Social Security Fairness Act. H.R. 82 eliminated the "Windfall Elimination Provision" and the the "Government Pension Offset". Bottom Line: Many public employees in the United States an…
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A Breakthrough for Americans Abroad: Lahood's Tax Bill Explained
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15:25December 20, 2024 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw AI description: "In this insightful episode, John Richardson and U.S. Tax lawyer, Virginia La Torre Jeker, delve into the newly proposed Residence-Based Taxation for Americans Abroad Act introduced by Representative Darin Lahood. The bill…
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Bitcoin, Expatriation, Roger Ver and the Exit Tax: A Legal Showdown
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23:01December 6, 2024 - Participants Include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw AI Description (with slight modifications): "Join John Richardson and Virginia La Torre Jeker as they dive into the riveting legal case involving Roger Ver, a pioneering figure in the world of Bitcoin, famously known as "Bitcoin Jesus." In…
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The Fair Tax Revolution: A New Era in American Taxation
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52:04November 30, 2024 - Participants include: Jim Bennett- Fair Tax Steven Hayes Fair Tax John Richardson - @ExpatriationLaw I have previously hosted Jim Bennett and Steve Hayes of Fair Tax fame. Previous podcasts are available here. Much has happened since our last discussion. The November 5, 2024 election of Donald Trump coupled with Republican contr…
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The Continuing IRS Interest In Foreign Gifts And Expatriation: A New Question On Form 8854 For 2024
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32:57
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32:57November 23, 2024 - Participants Include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw AI Description (with slight modifications): Part 1 - The Insanity Of "Foreign Gift Reporting" Continues "In this episode, join John Richardson and U.S. tax lawyer Virginia La Torre Jeker as they delve into the complexities of U.S. tax sys…
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