May 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 disposition of money, funds or other assets held in a financial account by direct communication (whether in writing or otherwise) to the person with whom the financial account is maintained."

Could the U.S. Treasury impose FBAR penalties on a U.S. citizen Pope for failing to include the Vatican's accounts on an FBAR? The answer to this question was the topic of our discussion today.

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AI Description:

In this intriguing episode, John Richardson from Toronto engages in a thought-provoking discussion with Virginia La Torre Jeker, a renowned U.S. tax lawyer based in Dubai, about the potential tax implications if a U.S. citizen were to become the Pope. The conversation delves into the complexity of U.S. tax laws, particularly FBAR (Foreign Bank Account Reporting), and how they could apply to a high-profile individual like the Pope, overseeing vast Vatican finances.

The dialogue also explores the broader implications for U.S. citizens in positions of international power, the intersection of religious institutions and U.S. tax obligations, and the potential hurdles a U.S. citizen might face in such globally influential roles. Topical questions about financial transparency, the Vatican's compliance under FATCA, and the hypothetical responsibilities of the Pope regarding U.S. taxation and reporting rules are also addressed, shedding light on the challenges of citizenship, taxation, and global politics.