PREP Podcaster - ”Success Favours The PREPared Mind”

July 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 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

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 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 ex...

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. AI Description:   "Think you know everything about a green card? Think again. In this episode, we explore the less-discussed side of holding a U.S. permanent residency: the lifelong ta...

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.   "In thi...

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 Simp...

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 holder...

July 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 Dive, we examine the controversial world of t...

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 he...

June 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 presentation. An AI description of her podcast is:   "In...

May 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 residents and citizens of other countries....

May 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 remittances sent outside the United States. It is eas...

May 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/   This podcast on May 16, 2025 continues our di...

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 chal...

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 asset...

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. ____________________________________________ A...

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. _____________________________________   Introduction … In 1980 Pr...

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 Dem...

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 dir...

March 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 episode, host John Richardson discusses pot...

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...

December 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 Toronto, Washington D.C., and France, they discuss...

December 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 and U.S. citizens living outside the United...