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PREP Podcaster - ”Success Favours The PREPared Mind”
Discussion about current events, culture, business, education, travel, death and taxes, etc.
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Episodes
Punitive Taxation of American Citizens Residing Abroad - From 1776 to 2026 06.07.2026 20:55
July 6, 2026 - AI generated from the following two sources: Current reality: https://citizenshipsolutions.ca/2019/03/12/the-united-states-imposes-a-separate-and-more-punitive-tax-system-on-us-dual-citizens-who-live-in-their-country-of-second-citizenship/ 1776 - The origins of America: https://web.archive.org/web/20260703132439/https://apps.bostonglobe.com/2026/07/storylab/250th-anniversary-bos...
IRS Removes Delinquent FBAR Safe Harbor — What It Means for Americans Abroad 02.07.2026 21:38
July 2, 2026 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw On June 30, 2026 the IRS removed its " Delinquent FBAR Submission Procedures " page, ending the informal (guaranteed) penalty-free route for taxpayers who had only failed to file FBARs but otherwise reported and paid U.S. tax on foreign-account income. The change means taxpayers now fac...
Why Americans Abroad Should Track The Activity And Income In The Canadian TFSA and Other Tax Deferred Foreign Accounts 10.06.2026 24:03
June 10, 2026 - Podcast generated from this post at the IsaacBrockSociety.ca https://isaacbrocksociety.ca/2026/06/09/tracking-income-in-your-tfsa-isa-or-other-account-that-is-not-taxable-in-your-country-of-residence/ ______________________________________________ AI generated podcast and description: "Tax Tracking Strategies for U.S. Citizens with Foreign Accounts 1 source·Jun 10, 2026 Ameri...
What Hath God Wrought: The FBAR Edition - A Trip Down Memory Lane From 2012 08.06.2026 20:58
June 7, 2026 - More on Mr. FBAR Podcast based on an old Phil Hodgen post from 2012 - Note how little has changed! https://web.archive.org/web/20130813183109/https://hodgen.com/what-hath-god-wrought-fbar-edition/ AI generated "This source criticizes the aggressive enforcement of U.S. international tax laws, specifically focusing on the Foreign Bank Account Report (FBAR) and its impact on dual...
Exempting Overseas Citizens From FBAR Filing Requirements 03.06.2026 18:55
June 3, 2026 - AI Generated podcast from: Why Treasury Should Exempt U.S. Citizens Resident Outside The United States From FBAR Filing - April 26, 2024 John Richardson, JD https://citizenshipsolutions.ca/2024/04/28/why-treasury-should-exempt-u-s-citizens-living-in-other-countries-from-fbar-filing/ AI generated description: "This source is an advocacy piece arguing that the U.S. Treasury sh...
US Renunciation Fee Slashed: Who Really Benefits from the Reduction In The Fee To Issue A Certificate of Loss of Nationality?? 01.06.2026 29:10
March 26, 2026 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw John Richardson interviews U.S. tax lawyer Virginia LaTorre Jeker about the State Department’s reduction of the Certificate of Loss of Nationality fee from $2,350 to $450 (effective April 13, 2026) and what that change actually means in practice. They discuss who stands to benefit (...
The Expired U.S. Passport: Proof Of U.S. Citizenship vs. Utility As A Travel Document 29.05.2026 20:21
May 28, 2026 - This is an AI generated podcast based on the following blog post at Citizenship Solutions: About The Expired U.S. Passport: Is It Proof Of Citizenship (Yes)? Or Can It Be Used As A Travel Document (No)? https://citizenshipsolutions.ca/2026/05/28/about-the-expired-u-s-passport-is-it-proof-of-u-s-citizenship-yes-can-it-be-used-as-a-travel-document-no/ The AI generated summary descript...
Fortress America: Citizenship, Mobility, and the Friction of Freedom 28.04.2026 20:20
AI generated podcast based on the Parviz Malakouti "X Spaces" discussion on April 27, 2026. https://x.com/ParvizMalakouti/status/2048849607879508090 "This transcript explores the concept of "Fortress America," a term used to describe the increasing legal and financial barriers that restrict the mobility of U.S. citizens. The speakers argue that an amalgamation of laws, including worldwide taxati...
"Subject To The Jurisdiction Of The United States" and The Future of 14th Amendment Birthright Citizenship 21.04.2026 22:22
April 20, 2026 - AI generated summary of an "X Space" discussion about the Trump v. Barbara case challenging "birthright citizenship" argued in the U.S. Supreme Court on April 1, 2026. A discussion of the oral arguments at the hearing are here: https://prep.podbean.com/e/ai-analyis-of-the-legal-arguments-presented-to-the-supreme-court-in-trump-v-barbara/ In a transcript from an April 20, 202...
The Undocumented Immigrant Tax: Taxation Without Benefits 17.04.2026 19:00
April 17, 2026 - Based on the work of Professor Francine Lipman Myth: The undocumented pay no taxes. Reality: The Undocumented pay higher taxes than legal residents. "Undocumented immigrantes operate as a massive fiscal asset!" Professor Lipman's article is available here: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1292960 "This text argues that undocumented immigrants pro...
Trump v. Barbara 2: AI Analyis Of The Legal Arguments Presented To The Supreme Court 02.04.2026 19:52
April 1, 2026 - AI generated discussion based on the transcript of the legal arguments in Trump v. Barbara Trump v. Barbara was a fascinating hearing. A moment ago I posted (as a podcast) the actual oral argument of what take place in the hearing. It is more than two hours long and may be heard here: https://prep.podbean.com/e/trump-v-barbara-oral-supreme-court-argument-april-1-2026/ This podc...
Trump v. Barbara 1 - Oral Supreme Court Argument - April 1, 2026 01.04.2026 2:08:29
April 1, 2026 - U.S. Supreme Court hears Trump v. Barbara - The Birthright Citizenship Case The question the court is asked to determine is: "Is birth on U.S. soil ALWAYS a sufficient condition to confer U.S. citizenship on that individual?" On April 1, 2026 the Supreme Court of the United States heard oral argument on this question. This "podcast" is simply a recording of the oral argument before...
Challenging the Constitutionality of US Citizenship Taxation 14.03.2026 15:40
March 14, 2026 - Podcast based on the following X Spaces discussion: https://x.com/i/spaces/1aKbdbMQDnRJX?s=20 Participants include: Dr. Laura Snyder - @TAPInternation Dr. Suzanne deTreville - @SdeTreville John Richardson - @ExpatriationLaw "This transcript features a discussion regarding a significant State Department notice that officially lowered the fee for renouncing US citizenship ...
America Slashes Citizenship Renunciation Fee From $2350 USD to $450 13.03.2026 19:34
March 13, 2026 - A "Deep Dive" Conversation generated from a podcast about the Isaac Brock Society blog post discussing the reduction in the fee for a CLN from $2350 to $450. https://isaacbrocksociety.ca/2026/03/12/effective-april-13-2026-the-fee-for-a-certificate-of-loss-of-nationality-should-be-450/ Description: "This text reports on a significant reduction in the administrative fee for obtain...
Second AI version: Foreign Tax Credits vs. the NIIT: What the Bruyea and Christensen Appeals Could Change 08.03.2026 9:14
A second and different AI generated podcast about the Bruyea/Christensen NIIT appeals ... based on a conversation between: John Richardson - @Expatriationlaw Tim Smyth - @TpSymth01 On March 3, 2026, the Federal Circuit heard back-to-back appeals (Bruyea — Canada and Christensen — France) over whether foreign taxes paid by Americans abroad can be credited against the 3.8% Net Investment Income...
Taxation Without Representation: Attacking The Voting Rights Of Americans Abroad 07.03.2026 19:36
March 7, 2026 - AI generated based on: "State of Play on Voting by Americans Abroad" https://aaro.org/images/pdf/STATE_OF_PLAY_2026_FEB_16_FINAL.pdf This 2026 white paper from the Association of Americans Resident Overseas (AARO) details escalating legal and legislative challenges to the voting rights of U.S. citizens living abroad. The report highlights federal bills like the SAVE and MEGA...
Treaty vs. Tax: Can the U.S. Sidestep International Credits? 04.03.2026 20:08
March 4, 2026 - AI Generated podcast based on my X Space with Tim Smyth. "Deep dive into two appeals heard March 3, 2026, at the U.S. Court of Appeals for the Federal Circuit challenging whether the Net Investment Income Tax (NIIT) can be offset by foreign tax credits despite a domestic statute that separates the NIIT from Chapter 1 credits. Using firsthand notes from courtroom observers, this e...
Christensen v. United States — The Foreign Tax Credit Showdown 03.03.2026 15:24
March 3, 2026 - Oral argument in the United States Court of Appeal in Christensen v. United States AI generated description ... "This episode covers the oral argument in Christensen v. United States, examining whether Article 24 of the U.S.–France tax treaty permits a foreign tax credit against U.S. tax beyond the Chapter 1 limitation and whether the Chapter 2A net investment income tax is c...
Bruyea - Treaty Tension: Does the U.S.-Canada Tax Treaty Cover the Net Investment Income Tax? 03.03.2026 46:28
March 3, 2026 - Oral argument in the United States Court Of Appeals In Bruyea ... AI generated description of the hearing: "This episode covers oral arguments in a case about whether the U.S.–Canada tax treaty allows a foreign tax credit to be applied against the U.S. net investment income tax (Section 1411), which Congress placed outside Chapter 1 of the Internal Revenue Code. Advocates debat...
Will You Still Receive Social Security After Renouncing U.S. Citizenship Or Abandoning Your Green Card? 02.03.2026 30:44
March 2, 2026 - Participants include: Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw ______________________________________ Introduction and purpose ... Entitlement to U.S. Social Security (including spousal and survivor benefits) after expatriation has always been difficult. During the months of January and February 2026 U.S. tax lawyer Virginia La Torre Jeker did a "de...
Supreme Court Slams the Brakes: No Emergency Tariffs for the President 20.02.2026 17:49
February 20, 2026 - AI Analysis of the Supreme Court decision striking down Trump's tariffs ... The Supreme Court said President Trump's tariffs policies under IEEPA are unconstitutional, dealing a major blow to the president's signature economic policy. Chief Justice John Roberts wrote the 6-3 opinion. Justices Clarence Thomas, Samuel Alito and Brett Kavanaugh You can read the actual Supreme Cour...
When Paper Profits Become Cash Demands: The Netherlands' 36% Deemed Tax Nightmare 18.02.2026 14:36
February 18, 2026 - Based on a presentation created for an IRS Medic podcast . AI generated description of the podcast .... "This episode unpacks John Richardson ’s February 18, 2026 presentation on "Deemed Income in the Netherlands," explaining how governments are shifting from taxing realized gains to taxing unrealized, deemed income. Using the Dutch Box 3 example (36% tax on deemed returns)...
Tax Treaty vs. Tax Code: Can the IRS Ignore Its Tax Treaty Promise? 11.02.2026 17:34
February 6, 2026 - Participants include: Dr. Suzanne deTrevile - @SdeTreville Tim Smyth - @TpSmyth01 Brent Vanderbrook - @Vanderbrook John Richardson @ExpatriationLaw https://citizenshipsolutions.ca/2026/01/09/bonjour-part-6-rosenbloom-and-shaheen-brief-in-support-of-bruyea/ AI Description: "This episode examines the legal battle over the Net Investment Income Tax (NIIT) and whether the I...
When an Income Tax Isn’t an Income Tax: Unpacking the Moore Case 06.02.2026 26:48
February 6, 2026 - Participants include: Professor Hank Adler - Chapman University John Richardson - Toronto, Canada - @ExpatriationLaw On January 29, 2026 Tax Notes published the following article by Professor Adler: "When An Income Tax Is Not A Tax On Income" The following podcast discusses Professor Adler's article ... AI generated description: "John Richardson interviews Professo...
When Home Taxes Chase You Abroad: Inside the 2025 Taxpayer Advocate Report 29.01.2026 1:08:02
January 29, 2026 - Participants include: Dr. Laura Snyder - @TAPInternation Dr. Suzanne deTrevile - @SdeTreville Tim Smyth - @TpSymth01 John Richardson @ExpatriationLaw Background: This week the Taxpayer Advocate released its 2025 report. Significantly the report included "Taxpayers Living Abroad" as one of the most serious problem areas encountered by taxpayers. The report is remarkab...
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