November 8, 2025 - Participants include:   Virginia La Torre Jeker - @VLJeker   John Richardson - @ExpatriationLaw   Prologue: 8 U.S. Code § 1401 - Nationals and citizens of United States at birth "The following shall be nationals and citizens of the United States at birth: (g) a person born outside the geographical limits of the United States and its outlying possessions of parents one of whom is an alien, and the other a citizen of the United States who, prior to the birth of such person, was physically present in the United States or its outlying possessions for a period or periods totaling not less than five years, at least two of which were after attaining the age of fourteen years: Provided, That any periods of honorable service in the Armed Forces of the United States, or periods of employment with the United States Government or with an international organization as that term is defined in section 288 of title 22 by such citizen parent, or any periods during which such citizen parent is physically present abroad as the dependent unmarried son or daughter and a member of the household of a person (A) honorably serving with the Armed Forces of the United States, or (B) employed by the United States Government or an international organization as defined in section 288 of title 22, may be included in order to satisfy the physical-presence requirement of this paragraph. This proviso shall be applicable to persons born on or after December 24, 1952, to the same extent as if it had become effective in its present form on that date; and"   The Podcast/discussion ... "To register or not to register, that is the question ... whether tis better to ..."   AI generated description:   John Richardson and tax lawyer Virginia La Torre - Jeker discuss the rights and risks when a child is born abroad to a U.S. parent — how citizenship is transmitted by law, the role of a Consular Report of Birth Abroad and U.S. passport, and practical issues like obtaining a Social Security number and traveling to the United States without having registered as a U.S. citizen. The episode also covers tax and reporting consequences (FBAR, FATCA, information returns), financial institution screening, dual nationality concerns, and planning options including later renunciation and steps families can take to reduce unexpected U.S. tax and reporting burdens.

October 8, 2025 - Participants include:   Tim Symthe - @TpSmyth01   David Bindel - @DavidBindelTx Dr. Suzanne DeTreville - @SDeTreville John Richardson - @ExpatriationLaw   "This episode examines the U.S. tax treaty "saving clause," which lets the United States deny treaty residency tiebreaker benefits to U.S. citizens and effectively causes double taxation for Americans living abroad. Speakers discuss history, practical harms (FBAR, pensions, capital gains), and a proposed executive-branch remedy: simply choosing not to invoke the saving clause so expats can rely on treaty tiebreakers, plus legal and durability considerations."  

October 1, 2025 - AI Generated Podcast ...   John Richardson - @Expatriationaw Presentation   "This episode explains the tough decision facing Americans living overseas: keep U.S. citizenship and face lifetime worldwide taxation and compliance, or formally renounce and risk immediate tax, estate, and immigration consequences. We break down the biggest hazards—the Section 877A exit tax, the "covered expatriate" tests (net worth, five‑year tax compliance, and income threshold), green‑card rules, retirement and Social Security issues, and planning strategies (including the dual‑citizen child exception). Seek expert legal and tax advice before acting."

September 24, 2025 - Participants include:   Virginia La Torre Jeker - @VLJeker   John Richardson - @ExpatriationLaw   The law of FBAR is found in Title 31 of the Bank Secrecy Act. Specifically 5314 is thought to define the FBAR obligation and 5321 prescribes civil penalties. The actual requirements are found in Regulation 1010.350. As a result of the recent IRS penchant for large penalty assessments, individuals have begun to explore the extent to which constitutional rights extend to FBAR penalties. Two constitutional issues which have (and continue to be) been explored are: 1. The eighth amendment excessive fines clause; and 2. The seventh amendment right to a jury trial. In September of 2025, a Texas court ruled in the Sagoo case that that the seventh amendment right to a jury trial extended to civil willful FBAR penalties. Whether the decision goes further is open to question. On September 24, 2025, U.S. tax lawyer Virginia La Torre Jeker, published an insightful article in Forbes titled: The Sagoo Case: FBAR's Reckoning In A Globalized World.   In today's podcast John Richardson and Virginia La Torre Jeker explore her article and what it could mean for future FBAR enforcement.   AI Generated description:     "Host John Richardson speaks with U.S. tax lawyer Virginia La Torre Jeker about United States v. Sagu (Sept. 19, 2025), a Texas district court fight over a $1 million FBAR penalty and whether taxpayers have a Seventh Amendment right to a jury trial for agency-imposed civil penalties. The conversation explains willful versus non‑willful FBAR standards (including willful blindness), how the IRS assesses penalties, the implications of recent Supreme Court precedent, and what the decision could mean for taxpayers with international accounts."

AI version of pdf presentation: John Richardson ____________________________________________ Warning!! This is a very complex area. I am not entirely happy with how AI generated this podcast. It's main. purpose is to highlight the importance of understanding your situation and getting proper advice!!   AI generated description:   This episode is a clear, practical deep dive into U.S. estate and gift taxes for people with international connections. We explain the three crucial taxpayer categories—U.S. citizens, U.S. domiciliaries who aren’t citizens, and non‑resident non‑citizens—how domicile is determined, and why U.S. situs assets (like U.S. real estate or U.S. stock) can trigger estate tax exposure. We then explore how treaties can dramatically reshape outcomes—highlighting the U.S. treaties with Australia and Canada—plus common planning issues like transfers to non‑citizen spouses and QDOTs. The key takeaway: your citizenship, intent to reside, and where assets sit determine whether your legacy faces tiny or massive U.S. tax bills, so careful cross‑border planning is essential to avoid costly surprises.

September 6, 2025 - Participants include:   Latife Hayson - Youtube.com/@LatifeHayson Dr. Karen Alpert - @FixTheTaxTreaty Dr. Laura Snyder - @TAPInternation John Richardson - @ExpatriationLaw   In July of 2025 Latife Hayson produced a lengthy video exploring the taxation of Americans abroad.    Latife Hayson and a SEAT members Karen Alpert, Laura Snyder and John Richardson  discuss the real-life consequences of U.S. citizenship-based taxation for Americans living abroad, covering capital gains, exchange-rate effects, PFICs, reporting burdens and financial restrictions. The conversation also explores practical advice for movers, the complexity of filing overseas, and prospects for policy change toward residency-based taxation.

September 5, 2025 - Participants include: David Coutts - @RealCoachCoutts   John Richardson - @ExpatriationLaw   AI generated description:     "John Richardson talks with Coach Coutts about turning 40, why strength matters for longevity, and how anyone—no matter their starting point—can begin improving fitness and mobility. They cover practical tips like walking, breathing, glute bridges, bird dogs, and prioritizing hip, shoulder-blade and core function to protect the spine and stay independent. The episode emphasizes habits, mindset, and simple, affordable ways to get started (YouTube workouts, short routines, buddies or basic books), and includes Coach Coutts's contact info at coachcoutts.com for listeners who want personalized help."

In February of 2015 I (John Richardson) did a presentation at a tax conference called:   "Sacred Trust: Counselling Clients Through The Trauma Of U.S. Citizenship Abroad in a "FATCAesque World"   I was curious to see what kind of podcast would be generated from the presentation. What follows is the result.   AI Generated:   "Imagine discovering that your U.S. citizenship — something you never actively chose — can create major financial, legal and emotional consequences while living abroad. This episode unpacks the shock of learning you are a U.S. person, the worldwide FATCA sweep that exposes you to banks and tax rules, and the life‑changing choices between remaining a citizen or expatriating. We cover the mechanics of U.S. citizenship determination, the costly compliance and exit‑tax risks, and the deep personal trauma clients face. The episode emphasizes the role of advisors in guiding vulnerable clients through both legal strategy and the emotional decisions that shape their futures."

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 in no way discusses the reality of citizenship taxation. To put it simply: A discussion of how citizenship taxation actually works and its effects on the lives of those inpacted by it is most notable in its absence.   AI description: "This episode dives into how global mobility, remote work, and tax competition are disrupting traditional tax systems and the social contract. We unpack the rise of non-dom regimes, citizenship-for-sale, and digital nomads who challenge where income is sourced and taxed. We explore the case for and against citizenship taxation—its promise to curb tax-motivated migration and its fairness claims—alongside alternatives like brain-drain taxes and exit taxes. Drawing on insights from Dagan and Mason, we probe what community membership really means and who owes what to whom. Using the United States as a reality check, we examine the steep enforcement and compliance hurdles (think FATCA) that make citizenship taxation a "luxury policy" even for powerful states. We then consider whether cooperation could help—while noting the risks for global justice, individual liberty, and a deeper race to the bottom. Finally, we spotlight a pragmatic path: combining citizenship and residence (and other indicators of belonging) to better align legal tax obligations with real community ties in a mobile world."

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, alongside experts Alex Ugorji and John Richardson, explore the intricate web of laws and obligations that trap individuals in unwanted citizenships, highlighting the often-overlooked complications of extraterritorial obligations. The discussion spans various geopolitical contexts, from the U.S. to Argentina, and delves into the unforeseen difficulties of acquiring and relinquishing multiple citizenships in today's interconnected world. Listen as experts debate the potential threats and strategic considerations for individuals seeking mobility and freedom in an era where citizenship laws are under increasing scrutiny. Discover why more citizenships might not always offer more freedom, the looming threat of legal obligations that transcend borders, and why relinquishing citizenship can be a daunting task. Whether you're an aspiring global citizen or just curious about international law, this episode offers valuable insights into a rapidly evolving landscape."

August 5, 2025 - Participants include:   Virginia La Torre Jeker - @VLJeker John Richardson - @ExpatriationLaw   Prologue: On June 11, 2025, the Department of Justice issued a memo indicating that it planned to prioritize the denaturalization of certain U.S. citizens. In early August of 2025, media reports began circulating describing a naturalized citizen, who was subject to denaturalization proceeds, based on tax related conduct. Generally the media reports failed to distinguish between the innocent tax mistakes made by the many and the willful violation of tax laws engaged in by the few. Podcast - AI generated description: "In this enlightening episode, host John Richardson and special guest Virginia La Torre Jeker tackle the complex and often misunderstood topic of denaturalization due to tax-related issues. Broadcasting from Toronto, John discusses the legal intricacies with Virginia, who provides insights from her recent Forbes article - "Tax Fraud And Denaturalization Risks - A Balanced View For Taxpayers". Through a detailed conversation, they differentiate between innocent tax mistakes and intentional tax fraud, highlighting the potential repercussions for naturalized U.S. citizens. Virginia emphasizes the importance of understanding these distinctions to prevent unnecessary panic amidst sensationalized media reports. Tune in as the duo explores the statutory framework of the Immigration Nationality Act, specifically focusing on the provisions that can lead to the revocation of U.S. citizenship, and reflect on historical case law that informs current interpretations. As tax professionals and legal advisors prepare to address public concerns, this episode aims to educate listeners, offering a calming and rational perspective on a challenging topic."

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 bill is discussed here: https://citizenshipsolutions.ca/2025/07/29/colorado-congressman-jeff-hurd-recognizes-problems-of-u-s-citizenship-taxation/ This was an interesting and lively discussion which considered how Americans abroad might make use of H.R. 4501 in their mission to end U.S. citizenship taxation.

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 exploit their version of he “saving clause” as a mechanism to employ U.S. citizenship taxation. The abstract of Dr. Parada’s paper includes: “The 'OECD Saving Clause': An American-Tailored Provision Made to Measure the World Rivista di Diritto Finanziario e Scienza delle Finanze, LXXVIII 1, I, 13-52 (2019) 41 Pages Posted: 18 Jul 2019 Leopoldo Parada King's College London Date Written: July 1, 2019 Abstract This article argues that the “saving clause” provision introduced in the 2017 OECD Model conflicts with the entitlement to double taxation relief under Article 23 OECD Model, especially in cases involving the use of hybrid entities. Although this issue is pragmatically solved in the new paragraph 11.1 of the commentaries on Articles 23A and 23B OECD Model, which provides no obligation for the Contracting States to relieve double taxation to the extent that taxation is based exclusively on the residence of the taxpayer, it leaves the taxpayer in the residence state with a potential permanent double taxation status. The foregoing may be however avoided with an optional “reverse saving clause”. Such an option seems to be not only more coherent with the traditional object and purpose of tax treaties (double taxation relief), but it also reflects the tax treaty practice already in force in some countries around the world.” AI generated commentary: "In this episode, we delve into the intricacies of global tax agreements, focusing on a fascinating provision known as the 'saving clause.' Introduced in the 2017 OECD Model Tax Convention, this provision allows countries to maintain their right to tax their own residents, even in the presence of a tax treaty with another country. We explore the surprising conflicts it creates with the goal of double tax relief, especially in the context of hybrid entities. Our discussion highlights the United States' historical use of the saving clause and its motivations rooted in unique taxation policies. We also contrast this with the 2017 OECD Model's approach and the issues it presents, particularly concerning hybrid entities that can lead to double taxation. The episode offers insights into potential solutions, like the 'reverse saving clause,' which aims to mitigate double taxation and promote fairness. Join us as we navigate through these complex dynamics and consider the implications for global business and personal financial planning."

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 tax obligations it entails. We uncover surprising insights with expert John Richardson, highlighting how a green card can bind you to U.S. tax requirements wherever you live. From understanding the divergence between immigration and tax statuses to navigating complex pre- and post-immigration planning, this episode acts as your guide through potential financial landmines. Discover the implications of worldwide taxation for green card holders, the criticality of pre-immigration planning, and the reality of holding foreign assets and income while living in the U.S. Understand what being a 'treaty non-resident' means and the tools available to those living abroad or looking to sever ties with the U.S. Hear about the criteria that determine 'long-term resident' status and the intricate processes involved in expatriation, including the looming threat of exit taxes and compliance with U.S. tax obligations. This episode provides a comprehensive guide to the myriad challenges that accompany a green card—far beyond just being a right to live in America."

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 this episode, we delve into the complexities of the U.S. taxation system imposed on its citizens living abroad. The discussion sheds light on how the U.S. tax code enforces a distinct, often more burdensome tax framework on American expatriates compared to their domestic counterparts. Through various examples and an insightful exploration, the episode reveals the challenges faced by these individuals, from punitive taxation on foreign income to the legal obstruction in utilizing foreign financial schemes meant for savings and retirement. We explore the multifaceted issues arising from citizenship-based taxation, where Americans abroad not only pay their local taxes but also grapple with unique U.S. tax rules that arguably disadvantage them. The episode highlights the disparity in tax treatment based on residency and the implications it holds for fairness and equality within tax legislation. Additionally, we look at the complex compliance requirements that place excessive burdens on these citizens, often prompting controversial discussions around renouncing citizenship. Join us as we examine the broader implications of these tax policies and their impact on global citizenship, raising questions about the intersection of identity, location, and global responsibilities in today's interconnected world."

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 Regulatory Fix For Citizenship Taxation 1 source This Tax Notes Federal article by John Richardson, Laura Snyder, and Karen Alpert examines the complex challenges faced by U.S. citizens living abroad due to America's citizenship-based taxation system. The authors argue that this system disproportionately burdens expatriates with duplicative and intricate tax compliance, often leading to double taxation and hindering their ability to engage in normal financial activities in their countries of residence. They propose that the U.S. Treasury has the regulatory authority and moral imperative to implement a "qualified nonresident" status, which would exempt these citizens from U.S. taxation on non-U.S. source income, thereby alleviating burdens on both expatriates and the IRS. Additionally, the article suggests several alternative regulatory changes to reduce specific compliance issues, such as those related to foreign bank accounts, retirement plans, mutual funds, and small business filings, highlighting that the IRS currently lacks the resources and expertise to effectively administer global tax enforcement.   What follows is the AI description of the podcast generated by Poedbean ...   "In this episode, we delve into the complex world of U.S. citizenship-based taxation and how it uniquely and often unfairly impacts Americans living abroad. Discover what it means to be caught between two tax systems and why the IRS is just as much a victim as the taxpayers themselves. We explore the persistent myths surrounding U.S. expats and the political challenges of enacting change. The episode highlights a potentially transformative regulatory solution that doesn't require congressional approval, aiming to ease the burden on both expatriates and the IRS. Tune in for a comprehensive discussion informed by a detailed study published in Tax Notes Federal, providing not only a sharp critique but also actionable solutions to a longstanding issue."

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 subject to punitive taxation on the loss of their status. Today (July 12/25), Virginia published a fascinating article in Forbes where discusses what could happen if a naturalized citizen is denaturalized. The immigration consequences are understood. What are the tax consequences of a U.S. citizen being denaturalized. What are the tax consequences of a a Green Card holder losing his/her immigration status? This raises questions of great interest. This podcast is a supplement to Virginia's Forbes article describing how this could work. https://www.forbes.com/sites/virginialatorrejeker/2025/07/12/bombshell-denaturalized-citizen-forced-to-exit-cant-escape-exit-tax/   AI Description:   "Welcome to our latest podcast episode where tax attorney Virginia LaTorre Jeker joins John Richardson to discuss a pressing issue: the U.S. government's efforts to revoke citizenship of naturalized Americans. While this may initially seem like an immigration issue, Virginia highlights the intertwining of tax and immigration laws, focusing on the possible tax implications for those who face denaturalization. The conversation navigates through the complexities of what losing U.S. citizenship means under expatriation (877A Exit Tax and 2801 Covered Gift) rules, exploring how these individuals face potential exit taxes. Virginia sheds light on how the tax code distinctly imposes punitive taxes on the  loss of U.S. citizenship, raising intriguing questions on the potential financial burdens, not just for those being denaturalized, but also for their families." We delve into real-world scenarios, legal precedents, and hypothetical situations to provide a comprehensive look at this multifaceted topic, tailored for both tax professionals and the general audience. Tune in for insights that may redefine the way you see the intersection of immigration and tax laws."

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 the Foreign Bank and Financial Accounts Report (FBAR) and its impact on U.S. citizens living overseas. Discover why the seemingly outdated FBAR rules, which mandate U.S. citizens to disclose their local bank accounts to the U.S. Treasury, are under renewed scrutiny. We'll explore whether these regulations still serve their original purpose and delve into the arguments advocating for a reconsideration of whom these requirements should apply to in our globally connected era. The discussion sheds light on surprising exemptions within the FBAR rules that often conflict with the heavy demands placed on expatriates. The episode raises pivotal questions about the role and meaning of American citizenship today, especially as it pertains to financial reporting. Join us for a thoughtful exploration of how FBAR is stirring debates and prompting some to contemplate renouncing their citizenship altogether."