May 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. citizenship taxation, exploring why legal challenges to FATCA often fail. The discussion emphasizes the distinction between addressing the symptoms of FATCA, such as privacy breaches and discrimination, and tackling its root cause: U.S. citizenship-based taxation.

The episode scrutinizes the implications of the U.S. imposing tax obligations on citizens residing abroad, questioning whether this practice aligns with international law principles. It argues that U.S. citizenship taxation expands the U.S. tax base globally, often conflicting with the tax sovereignty of other nations and potentially violating customary international law (CIL).

Listeners are encouraged to consider whether U.S. citizenship taxation, which bases tax residency on citizenship rather than physical or economic ties, is an outdated practice incompatible with modern international norms. The podcast aims to spark a broader discussion on the need for tax reform, particularly for Americans living overseas.

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.

April 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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A truly fascinating discussion primarily by Brent Vanderbrook about the "ideology" of U.S. citizenship taxation.

How does one engage in a discussion with people inside the USA (particularly US Treasury) about changing citizenship taxation?

April 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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Introduction …

In 1980 President Jimmy Carter filed a report on the topic of "U.S. Law Affecting Americans Living and Working Abroad".

The Carter report was …

“A legislative effort by Senator George McGovern required the President to conduct a thorough study of laws governing U.S. citizens abroad. This report by President Jimmy Carter was the first under that law - a painstaking review of the many legal provisions affecting U.S. citizens residing abroad. Issues include loss of citizenship by children born abroad, income tax, social security, veterans benefits and many other matters - and very little has changed since this report was written, so this is still a valuable legal guide for any American taking up foreign employment or residence.”

The book is available here.

It is a fascinating report in terms of its content. In addition, to the content it reveals the impressive work done by "American Citizens Abroad" in its formative years. Significantly, many of the problems that exist today were identified in 1980. Very little has changed for the better.

Significantly the report is based on a world BEFORE:

• FBAR enforcement AKA The Obama/Biden “FBAR Fundraiser”

• the creation of the PFIC rules in 1986 (Reagan tax reform)

• Obama/Biden FATCA in 2010

• the Clinton Treasury Foreign Trust rules of 1996

• the Clinton Entity classification regulations of 1996

• the Obama OVDI/OVDP programs beginning in 2009

• Trump administration Transition Tax/GILTI rules of 2017

Note that EVERY ONE of these things is the result of U.S. citizenship taxation.

The ONLY solution is a complete separation/severance of citizenship from tax residency. Hate to say it, but there is NO OTHER option.

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On April 12, 2025 Dr. Suzanne de Treville led a discussion about the Carter report. Her discussion specifically referenced a presentation and spreadsheet which are at the following two links:

https://docs.google.com/presentation/d/1_fN0iCzcBhftbiemFYEm9B7dQsCQp9O8bV7D0a70JV8/edit?usp=sharing

March 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 Rebecca Lammers, the chair of the Democrats Abroad Taxation Task Force, as they discuss recent developments affecting U.S. citizens living in the U.K. In this special episode, Rebecca sheds light on the ongoing consultation by the U.K. Financial Conduct Authority and its implications for investment products like ETFs and mutual funds.

The discussion emphasizes the difficulties faced by U.S. citizens in the U.K. in purchasing these financial products due to differing regulatory requirements. Rebecca highlights her personal submission for the U.K. government, striving for reforms that could ease these barriers and foster investment opportunities for U.S. expats. Tune in to explore how these potential changes may pave the way for a more accessible investment landscape."

March 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 disconent.

The IRS response was surprising direct and "in effect" invited Americans abroad to engage in a "rulemaking process" to achieve the needed change.

https://seatnow.org/2025/03/17/treasurys-response-to-form-8621-comments-the-good-the-bad-and-the-ugly/

Here is m discussion with Rebecca Lammers who heads the Democrats Abroad Taxation Task Force.

AI Version

"In this episode, John Richardson and Rebecca Lammers, head of the Democrats Abroad Taxation Task Force, discuss the recent IRS response to public comments on Form 8621, known for its complexity and impact on Americans investing in foreign mutual funds. Rebecca shares her insights on the advocacy efforts to reform these tax rules and the steps being taken to hold the IRS accountable for their treatment of Americans abroad. The conversation also explores potential tax reforms for U.S. citizens living overseas and the ongoing legislative efforts to address these issues.

The discussion highlights the challenges faced by Americans investing abroad, focusing on the PFIC form and the IRS's detailed acknowledgment of these challenges in their recent response. Rebecca also explains the importance of getting things on the record as part of advocacy to push for necessary reforms and the potential pathways to initiate a formal rulemaking process. Additionally, they touch upon the Residence-Based Taxation bill and the complexities surrounding its passage in Congress, offering insights into the legislative process and the need for continued support and awareness among the American expatriate community.

Finally, they discuss the financial and volunteer support needed for continued advocacy and reform efforts, inviting listeners to contribute and get involved through Democrats Abroad and other organizations working towards fair taxation for Americans abroad."

March 11, 2025 - Participants include:

Virginia La Torre Jeker - @VLJeker

John Richardson - @ExpatriationLaw

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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 episode, host John Richardson discusses potential U.S. tax reforms with renowned tax lawyer Virginia La Torre Jeker. Together, they delve into a fresh memorandum suggesting significant changes that could impact Americans living abroad.

Part A of Virginia's insightful blog post outlines proposals directly aimed at alleviating the tax burden on expatriates, while Part B explores unexpected benefits from proposed reductions in corporate tax rates.

The conversation reveals contrasting approaches to tax reform, including debates around increasing the foreign earned income exclusion and the more radical idea of exempting all foreign income from U.S. taxes. The duo also examines inadvertent advantages these reforms could provide for expatriates, especially through lowering the U.S. corporate tax rate.

Amidst discussions on the complexities of tax obligations for Americans overseas, Virginia sheds light on the intricate Controlled Foreign Corporation and GILTI tax regimes. Listeners are encouraged to explore these reforms' broader implications, as John and Virginia consider an optimistic outlook for future changes in tax policies."

January 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 exit provisions, focusing on the significant implications of the 2801 Transfer Tax. As they delve into the intricate regulations established by Congress through the 877A exit tax provisions and the 2801 covered gift tax provisions, John and Virginia provide an essential guide for expatriates and their families.

The discussion highlights the burdensome regulations imposed by the U.S. tax code, especially for covered expatriates, and elaborates on what it means to be a covered expatriate. Virginia explains the various criteria and tests that determine one's status and discusses the significant penalties for non-compliance, including the harsh covered gift tax requirements. They also explore practical strategies for individuals facing these issues, detailing what it means to avoid or manage covered expatriate status.

Furthermore, the episode examines the broader implications for U.S. citizens abroad and their families, urging them to stay informed and seek professional guidance to navigate these complex tax obligations effectively. The conversation serves as a crucial reminder of the importance of meticulous preparation when it comes to U.S. tax obligations and estate planning for those living outside the United States."