ExpatriationLaw - X Spaces Lives Discussions - Ending Double Taxation Of Americans Abroad

Speakers include: Dr. Laura Snyder Dr. Suzanne deTreville John Richardson Tim Smyth The Compliance Crisis: 2025 Report on Americans Abroad 1 source This transcript features a discussion among advocates regarding the 2025 National Taxpayer Advocate Report , which officially identifies the severe compliance burdens facing Americans living abroad as a major problem. The participants highlight how the...

The Compliance Crisis: 2025 Report on Americans Abroad 1 source This transcript features a discussion among advocates regarding the 2025 National Taxpayer Advocate Report , which officially identifies the severe compliance burdens facing Americans living abroad as a major problem. The participants highlight how the U.S. citizenship-based taxation system creates “second-class citizens” who struggle...

In a recent legal discussion, experts analyzed the landmark Supreme Court case Afroyim v. Rusk , which established that the government cannot strip a person of their citizenship without their specific intent to give it up. The speakers highlighted how this ruling provides constitutional protection for dual nationals, making it significantly harder for the state to involuntarily revoke an individua...

This AI generated podcast is based on a SEAT post announcing our latest article published in Tax Notes. The article explains how President Trump’s pledge to end the double taxation of Americans abroad can be achieved by the U.S. waiving it’s “saving clause” rights under the treaty. https://seatnow.org/2025/10/06/a-simple-and-unilateral-treaty-fix-for-citizenship-taxation-richardson-snyder-and-alpe...

Tim Symthe - @TpSmyth01 David Bindel - @DavidBindelTx Dr. Suzanne DeTreville - @SDeTreville John Richardson - Expatriation Law This podcast is largely based on a post that appeared on the SEAT site at: https://seatnow.org/2025/10/06/a-simple-and-unilateral-treaty-fix-for-citizenship-taxation-richardson-snyder-and-alpert/ “This episode examines the U.S. tax treaty “saving clause,” which lets the Un...

This is an AI generated podcast from a presentation I created. The AI description of the presentation is: Renouncing US Citizenship: Reasons, Rules, and Risks 1 source “The provided document, primarily authored by John Richardson, offers a comprehensive guide to the decision and process of renouncing U.S. citizenship , focusing heavily on the complex tax implications for expatriates and long-term...

This is a public episode. If you would like to discuss this with other subscribers or get access to bonus episodes, visit expatriationlaw.substack.com

I thought it would be interesting to have AI create a podcast of Professor Edward Zelinsky’s 2024 paper titled: Defending U.S. Citizenship-Based Taxation in Theory and in Practice: An Essay on Fiscal Citizenship in a FATCA World Here is the AI description: “Defending Citizenship-Based Taxation in a FATCA World 1 source The provided text is an academic essay arguing in favor of the United States' c...

The following AI Generated podcast is based on a presentation that I delivered 10 years ago in London, UK . Not much has changed. Here is the AI generated description of the presentation: Sacred Trust: Counselling Through U.S. Citizenship Trauma Abroad 1 source The provided text, "Sacred Trust: Counselling Clients Through the “Trauma of U.S. Citizenship Abroad” in a FATCAesque World," by John Rich...

4 minutes ago August 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 taxation as a theoretical concept. It...

August 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 insightful episode, recorded on August 8th, Malakouti, al...

July 30, 2025 - Speakers Include: Dr. Laura Snyder - @TAPInternation Parviz Malakouti - @ParvizMalakouti BitCoin Backpacker - @BitCoinBackpacker 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 the Internal Revenue Code. Congressman Hurd’s...

July 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 This is a public episode. If you would like to discuss this with other subscribers or...

July 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 - @ExpatriationLaw This is a public episode. If you would like to discuss this with other subscribers or get access to bonus episodes, visit expatriationlaw.substack.c...

Warning!! This is incredibly technical and is NOT for the “faint of heart”. The 2017 TCJA - repealed IRC 958(d)(4). All of a sudden many corporation became CFCs. The 2025 “OBBB” - The U.S. taxation of “U.S. Person” shareholders (whether individual or corporation) continues to become more complex. The “OBBB” created a new “form” of of Subpart F income. The is described in 951B. 951B is a direct rea...

This 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 controlled foreign corporations. The U.S. treaties exp...

This 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. The AI description of the presentation was: The Green Card: Navigating US Tax Residency and Expatriation 1 source This document provides an overview of the U.S. Green Card , focusing o...

This 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 generated description of the article. Punitive US...

In 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 AI Description of the article. A Simple Regul...

July 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 holders. Both citizens and Green Card holders are...

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 …. Exempt Non-Resident Citizens From FBAR: A Crucial Argument 1 source The source critiques the Foreign Bank and Financial Accounts (FBAR) reporting requirements, specifically...

This is an AI generated podcast based on the following X.com thread from June 19, 2023: https://threadreaderapp.com/thread/1670801303306477571.html This was motivated largely by my lunch meeting with Jim and Christine Bennet: https://x.com/ExpatriationLaw/status/1669784804429053952 Here is the AI generated description of the X.com thread: The FairTax: A Solution for Americans Abroad 1 source The p...

This 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 (“Digital Services Taxes”). The U.S. objection to DS...

June 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 the slides used) may be found in the blog post here...

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 presentation. An AI summary of her presentation is: "In this episode, Laura Snyder delves into the intricacies of immigration, exp...