Debunking Harvard Law Review's Misrepresentations on Americans Abroad And The U.S. Exit Tax

SEAT has prepared a new survey and is asking both current and former Americans abroad to participate. Advocacy for Americans abroad is greatly enhanced by the availability of current information. The survey is on the SEAT site:

 

https://seatnow.org/2024/06/14/tell-your-story/

 

________________________________________

 

June 25, 2025 - Participants include:

Dr. Karen Alpert - @FixTheTaxTreaty

Anthony Parent - @IRS_Medic

Keith Redmond - @Keith__Redmond

Dr. Laura Snyder - @TAPInternation

John Richardson - @Expatriationlaw

 

A recent post by Paul Caron:   https://taxprof.typepad.com/taxprof_blog/2024/06/harvard-law-review-moore-section-877a.html   The Note published in the Harvard Law Review disparaging Americans abroad:   https://harvardlawreview.org/print/vol-137/moore-than-meets-the-i-r-c-the-apportionment-rules-originalist-backstop-for-i-r-c-%c2%a7-877a/   SEAT's response to the Note :   http://seatnow.org/2024/06/22/harvard-law-reviews-drive-by-attack-on-overseas-americans/     Harvard Law Review declined to publish Snyder's response to the Note. This podcast discusses both the Note and Harvard Law Review's failure to publish any correction of the Note.

 

AI Description:

 

"Join John Richardson and a panel of experts as they dissect the recent Harvard Law Review note that attempts to defend the constitutionality of the U.S. Exit Tax. The episode features Anthony Parent from the IRS Medic podcast, along with SEAT members and co-founders Keith Redmond, Karen Alpert, and Laura Snyder.

The discussion kicks off with an overview of the Exit Tax, a levy imposed on Americans renouncing their citizenship to escape U.S. taxation. The panel critiques the Harvard note for its factual inaccuracies and defamatory statements about Americans living abroad. They argue that the article misrepresents the reasons behind renunciations and fails to consider the complex compliance issues faced by expatriates.

Further, the conversation explores the broader implications of the Harvard Law Review's stance, the need for severing citizenship from tax residency, and the potential unconstitutionality of the Exit Tax post-Moore decision. The panel also highlights the importance of advocating for the complete severance of citizenship from tax residency to solve the problems faced by Americans abroad.

Tune in for an insightful debate on the flaws in the Harvard Law Review note and the broader issues of U.S. taxation on expatriates."

Episode Transcript

(00:01):
Good morning, this is John Richardson speaking with you from Toronto, Canada.
Today is Tuesday, June the 25th,
2024, one day after the release of Julian Assange has been announced.
So this is an important day for many reasons, but we're not here to talk about
that specifically today.

(00:21):
Day joining joining me today
are following anthony parent
runs the irs medic podcast and see
members and co-founders keith redmond
and i guess washington dc at the moment karen alpert in australia where it's
the evening and laura snyder in paris where it is midday so just think These

(00:46):
issues are of interest to people all around the world, and the sun,
if you will, never sets on the need to discuss the issues that we're here to talk about today.
This is our last podcast, podcast on request.
Laura, what are we here to talk about today? day? Two things.

(01:07):
Well, three things even, but I'll start with two. The first one is that back
in February, the Harvard Law Review published a student note that talks about,
tries to defend the constitutionality of the exit tax.
And in doing so, basically defames Americans who live outside the United States

(01:29):
and makes demonstrably false assertions and implications about them.
Hold on. Let's just stop you there. Keep exactly where you are.
Some people might not know what the exit tax is. Anthony, it seems like a good
moment for you to chime in. What's the exit tax anyway?

(01:50):
The exit tax is the ransom you have to pay to the U.S. government to leave in
order to escape U.S. taxation.
Karen, can you explain that in a little more factual, objective detail?
I do I do agree with Anthony, but somebody else might not care.
Yes, it's what you pay to get out from the U.S. tax system.

(02:12):
So the U.S., of course, taxes based on citizenship, not just residence,
unlike every other civilized country in the world. And so...
When you leave the U.S., that's not a tax event. You're still,
if you're a U.S. citizen, you're still subject to U.S. taxes.
But if you cease to become a U.S. citizen, then you all of a sudden are no longer,

(02:37):
and you're not living in the U.S., you're no longer subject to the U.S. tax system.
And at that point, the U.S. wants to say, hey, we want to make sure we get our share.
So they put in a an
exit tax that applies when you give
up your citizenship not when you leave the country am i
right saying this exit tax is based on a fictitious sale of assets and a fictitious

(03:04):
distribution of pensions and stuff in other words are these are these uh fake
events they're making up to impose right exactly so if if you're subject to
the exit tax and there's three criteria.
We've gone over them several times, but for most people who live outside the
U.S., it's basically if you're rich,
and their idea of what's rich is interesting because it's not enough to retire

(03:29):
on in a lot of countries around the world.
But if you're rich, then the IRS or the U.S.
Tax code is basically going to say, hey, let's pretend that you sold all of
your assets that generate a capital gain and that you have distributed all of

(03:51):
your non-US retirement accounts and pensions.
And then let's just put that all on one tax return, and we're going to tax it now.
For the capital gain assets, we'll give you an exemption for,
I don't know what it's up to now, somewhere around $800,000,
I think, because that is indexed.

(04:12):
But for your foreign retirement accounts and pensions, there is no exemption at all.
So we're going to just treat that all as taxable the day before you renounce.
All on one tax return, you're going to be at the top marginal tax rate if you're
subject to this, most likely, especially if you've got a pension of a few hundred

(04:35):
thousand or more, probably more,
that's being distributed all at once. All right.
Would anybody disagree with the following characterization?
Let me try to just summarize this. If anybody disagrees, perhaps say why,
but would you say that listening to Anthony,
listening to Karen, that what the exit text really is, is an attempt to confiscate

(05:02):
a portion of the assets of somebody who renounces U.S. citizenship. Is that correct?
Yeah. John, I would just add on that not only is it intended to confiscate,
but it's intended to keep people in because of the fear of paying the tax.
So it works as, hey, look, if you leave, you're going to be punished,
but that's why you don't want to leave. So it's a way to keep people in as well.

(05:23):
So that's the restriction that it has on escaping the US, which cracks me up
because if this was the 80s, I remember the 80s, oh, America's freedom,
and look at all these defectors from the Soviet Union coming here.
We're the land of opportunity.
Look at them over there. They have to have that iron curtain,
but hey, we're free. We keep our iron curtains hidden, right?

(05:43):
That's the American way. We're a little bit more passive-aggressive about the whole thing.
Well, I mean, America confiscates the assets through the tax.
Other countries perhaps just confiscate assets.
The big problem with this is that it happens probably years after you actually
physically left the U.S.

(06:05):
In fact, you may never have even been in the U.S. You might have become a citizen
because your parents were citizens.
And you were born in France or someplace.
Yeah, let's pause on that point and bring Laura back. Keith,
is there anything you want to add at this point?
Not at this point. You guys are spot on. Okay.
This is a good moment, I think, to bring Laura back into the conversation.

(06:28):
It seems to me that this article.
Made some comments in this context, right, about people leaving the United States
as opposed to living outside the United States and stuff. Is that the case, Laura?
Yes, it begins with basically, you know, false defamatory statements about Americans

(06:48):
who live outside the United States and people who renounce and why they renounce. Yes.
Okay, my reading of the article was that, you know, you have this image of somebody
leaving the United States and renouncing, not living outside the United States
for years and renouncing.
That's exactly the image it portrays. Exactly. And that's one of the multiple

(07:12):
problems with the article.
Okay. Now, that's a problem with the article. But would it be fair to go further
and say that that is significant, possibly intentional distortion of reality,
that, in fact, undercuts the value of the article, period?

(07:33):
I would tell you, yes. And I want to tell you and give you an example as to
why I support the word intentional.
The author of this article cites Cluth's article that he wrote a while ago about
why Americans are renouncing.
And so it's quite clear he read that. And Kluge did a very good job in that

(07:56):
article by describing all the compliance problems that people have.
So the author of the Harvard Law Review note just ignored all of that.
So, yeah, I think you can conclude it was intentional.
Interesting. I would add also, this is supposed to be good scholarship.
This is considered the most influential law journal in the country.

(08:20):
There is a lot of information out there about what happens, how people renounce,
why people renounce, what the process is, you know, a lot of information out there.
The only thing this article cites is Klutz's article.
They didn't, it's clear they either didn't look at that information or didn't

(08:40):
care about it, whatever.
Whatever, this is supposed to be exemplary scholarship, and it ignores everything
that is overwhelmingly demonstrating that the way this article opens is wrong.
Okay, so let's continue on, Laura, beyond that point. Basically,
what happens is that the article proceeds from essentially a completely fictitious,

(09:07):
misleading set of assumptions, right?
Yes, and it needs to do that because it wants to defend the constitutionality of the ISIS Act.
Well, if you're going to defend the constitutionality of it,
you probably want to, you know, do this on the assumption that it's moral.
And you can't do that on the assumption that it's moral, but this article pretends that you can't.

(09:30):
In the article, they use Boris Johnson as one of their cases because Boris Johnson
said it's absolutely outrageous.
But they don't give you the context that Boris was born in the U.S.
When his parents were graduate students and moved back to the U.K.
Before he started school and has never lived in the U.S.

(09:55):
Since then. him so he's more shots a
dual citizen by birth as well yeah but that
doesn't get him out of the ongoing income tax unless
he renounces sure it was the ongoing income tax that he was saying was outrageous
which is why he renounced right but but the point is that you know here we're

(10:17):
having our pension intellectuals our little factory up there in cambridge claiming
that people are are are taking advantage of this exit tax missing,
missing a key fact here that, Hey, look in America, guess what?
We can completely discriminate based on your circumstances of birth.
If you are a dual citizen by birth, you get this special treatment.
But if you are a U S citizen, Oh, you're going to get it.

(10:39):
And that's something that's completely missed by Harvard, right?
Because why would they, why would they be interested in covering the truth whatsoever?
Their entire point, the entire point of Harvard is to justify the,
the existence of the U S government, as is Yale, as is Yale.
Yale is right down the street from me. And let me tell you something about Yale
most people don't understand.
It is CIA central.

(11:00):
The CIA created Yale. The Bush family is Yale. I mean, that's Yale.
Skull and bones is Yale. And I have friends at Yale New Haven Hospital.
They say the CIA is in there so much doing what, and this is what they're doing
because people are like, no, they're nuts.
They're just advancing the government's narrative. That That is what they're
doing. And we see it's plain as day here.

(11:21):
It's plain as day. What these Ivy League schools do is they advance the government narrative.
And if you are a participant in the Ivy League to advance the government narrative,
now there's that sweet plum job at whatever it is, the sweet plum job at the
government that your whole family would be proud of.
And now you could be part of the entire tyranny against the American people.

(11:43):
So actually, I was thinking about this. I was thinking about the proposal that
I have is to ban the Ivy League from government.
If you are an Ivy League graduate, you are banned from any government employment.
And I think if you think about how much freedom and how much better our government
would look without the Ivy League...

(12:03):
Doing what it's been doing to us. I mean, come on. It just goes on.
And here it is. It's so overt.
It is so overt what they're doing. And all of these pension intellectuals,
they take their marching orders from the government.
There's no separation between them. They are just there to launder,
launder the government's ideas to try to impact public discourse.

(12:27):
And here they go so far. You know, and this is how I look at my mind,
why I know this is a government project is because it's so bad,
because the quality is so low, they couldn't even come up with better arguments,
it couldn't even do, they didn't even have the effort.
So it's a low effort issue by some of you by people who are used to having things go their way.
You know what? I'd like to add something here as well, because I think it's

(12:50):
not just that, because there is this patriotic embedding or brainwashing that also is part of this.
Because what I was shocked about this Harvard Law Review article is it's no
different the way it was written than a biased journalist.
Because I remember back in 2013, a CNBC article on their website came out under

(13:13):
a similar type of subject matter that I did respond to,
and they did accept it. But it was the same thing.
It's this biased view of the U.S., its government, et cetera.
So it's not just at the— Here from the article.
From which article, Karen? From the Harvard article that we're critiquing today,

(13:37):
talking about the people who had so little regard for their citizenship, or that they...
They presumably valued their citizenship so cheaply
to have sacrificed it for any area game exactly
and you know and i'll be honest with you i am not
one i'm not a conspiracy type of guy that's just not my thing

(14:00):
but i truly believe that there is
this quote-unquote conspiracy going on that
like anthony was saying at the levels of university but also
at the level of journalism capitalism i've you know and
in this article i was talking to you about was 2013 i know but it's just becoming
more and more egregious you know you know we we have a case coming out it's

(14:22):
going to be really soon about you know how much the the government can manipulate
social media so we know the government wants to manipulate we we know that and
they think well we should be allowed to.
And and that you know we're severely hamstringing the government if we actually
pay attention to the first amendment.
So we know we have a government that doesn't respect the first amendment whatsoever, whatsoever.

(14:42):
They want to create the news. And I mean, this, this is, and they get away with it, right?
Because who's reporting on them breaking the law? Oh, oh, it's us.
And we've exonerated ourselves.
And so we're just seeing the wheels come off. You know, we're seeing the wheels
come off the whole, the whole propaganda wagon here as the government sort of revealing themselves.
And I think this is good news in a way because this article is so bad.

(15:05):
It's so bad that you
know you really have to be a true believer you have
to be so divorced from reality really you have to be in
your little your little your little your little bubble inside your little Ivy
League place and then you go to Washington DC DC it's the same bubble it is
this bubble exactly if I could make a couple comments first one is this technically is a

(15:31):
note and not an article. What's the difference?
In law reviews, notes are written by law students, usually current law students
enrolled at that university in that law school at that time, usually.
And articles are written by basically people from outside the university.
Not necessarily outside the university, but academics, usually academics,

(15:53):
but can also be judges or practitioners.
This is a student note. Now, what I would add about this, and this is where
Harvard Law Review is different from most other law reviews,
Harvard Law Review's notes are anonymous.
They're not signed. If you look at their notes, you will not find an author.
You will on the article, but not on the notes.

(16:15):
And I would say to respond to what Anthony just said, he's right about people being in a bubble.
There's an additional problem to this kind of article.
There's people that are not familiar with these issues, but that think that
they should respect the Harvard Law Review and what's published there.
They will read this and they will believe it. And this is the second and the

(16:40):
biggest problem with this article is the fact that I submitted a response to it.
I don't know if anyone else did. Maybe someone else did.
I have no way of knowing, but I know that I did. I know that Harvard Law Review
sat on my response for four months, and then at the end of the school year,
basically sent me a short email

(17:02):
with no explanation, just saying that they're not going to publish it.
To me, that is worse than the publication of this original article.
If you you're not going to accept a
correction and publish a correction of what is obviously factual
factual mistakes in this article not
just a disagreement of opinion but factual mistakes that are defamatory of overseas

(17:25):
americans and you don't accept to publish a correction that is much worse than
the publication of the original note right here's a question but excuse me i
got a question here's a question for you laura your response was rejected okay OK,
were there any responses published to this article?
Not that I've seen. That's what I mean. I don't know if others submitted one

(17:47):
and they were also rejected or if no one submitted that.
I have no way of knowing, but I've not seen any sort of responses,
anything published to there.
OK, so here's a suggestion on this, everybody. Here's a suggestion. What about.
Resubmitting laura's laura's response
to this thing but resubmitted from a

(18:09):
2 000 individual americans abroad
i'd have to take it down from online
their rules are their rules are technically it can't be something that's already
been published just rewrite if that's all or you know or something like that
but i mean you know it seems to me that you know they can get away way with
this if all they do is they send Laura a get lost email.

(18:33):
But if the response is first.
The response is first publicly circulated, all right, or at least people are
aware of it, and then the request to publish the thing comes in from a large
number of people, I think it might be much harder for them to ignore.

(18:53):
And I would suggest that that might be a good way a good way
to go about this i mean they can easily blow laura off but
they can't well actually that's not so easy to blow laura off you
know i mean she's persistent but i think it's a lot harder for them to ignore
a very large number of people and perhaps that should be the next step but john

(19:15):
john would you add excuse me john would you add that maybe it might be It would
be good to send it to the editor of the Harvard Law Review who oversees this.
The editor's seen it. What I find amazing is she's an African-American woman.
And I would think that I'm kind of surprised that she would allow such a blatant,

(19:37):
broad stroke of a population of Americans.
You know what I mean? Keith, I don't agree with that.
What do you mean? Just because someone's black, you think they're going to be
on the side of truth and justice?
No, no. But I would think it at least might have something in her mind.
I don't think you understand how it works, Keith. Well, no, no,

(19:59):
I do understand how it works.
I know populations are not vital, but I get that.
The whole point when you get into the elite school is, hey, you're part of it.
It doesn't matter what your background is. Everyone becomes the same thing.
So it supersedes whatever. I think if you're going to become an editor of the
Harvard Law Review, you already have a certain mindset.

(20:23):
Otherwise, you're not going to be allowed to have that position. Right. Yes.
There you go, Laura. Perfect. Perfect. So everybody, the basic starting point is wrong.
And what they're saying is that basically, hey, people are renouncing the same
taxes. They don't value their citizenship.
The truth of the matter is that the United States is forcing people to renounce

(20:45):
and then confiscating their assets on the way out the door. Isn't that a more accurate narrative?
Yes. Yes. So, I mean, that I think is the fundamental sort of factual disagreement here, right?
Harvard, in the world of the Harvard Law Review, okay, people are renouncing to save taxes.

(21:10):
They don't value their citizenship. In the real world, American citizens,
many patriotic American citizens are being forced to renounce.
And as part of the process, their assets are being confiscated.
So I think that's part of the point that needs to be made here.
But anyway, continuing on, Laura.
Continuing on with Laura. Well, I think I've said,

(21:30):
you know, I explained what I think the, you know, the biggest problem here is
and why I think we thought it worthwhile to have this discussion is the fact that,
you know, Harvard will publish lies and not correct them.
And I do agree, Laura. They are, you know, as ridiculous as,
and you're right, because we read this and we can see how utterly depraved and

(21:53):
amoral this is. We can look at it, but you're right.
There is going to be some clout that comes with Harvard Law Review and some
people, you know, a general lawyer who doesn't know, you know,
a lawyer who doesn't know too much about U.S.
Taxation could just look at this and say, oh, wow. Oh, wow. Yeah.
These, you know, they're just leaving because they value their citizenship cheaply.

(22:14):
I mean, you got to love it. But you got to love it. The country,
the country and the institutions that make our citizenship so cheap,
so worthless, so worthless. We want to get rid of it. Right.
I mean, we didn't make it cheap. We didn't make it cheap.
Rather, it's this entire Ivy League government intersection of interest and

(22:36):
alignment of interest, which they won't tell us the truth about.
Right, Anthony, but would you also agree, in a concert with what you're saying,
that it's also very difficult to pierce that patriotic, nationalistic wall that
seems to metastasize not only at universities,

(22:57):
but what I was saying is with journalists,
etc., that that's such a hard thing to overcome.
And that's been a major problem with this whole thing. Well,
but Keith, and I would say you're absolutely right. That's difficult to overcome.
But maybe somebody on this call...
Didn't maybe have seen the light too, that maybe there was some patriotic nonsense,

(23:20):
I believe, in maybe 2002, 2004.
And then the truth is revealed to you through various red pills.
And then you realize what our government actually is.
And then if you practice tax law enough, you find out what this government actually is.
So I would say I've had my own awakening, Keith, because that patriarchy is
certainly something I was a part of.

(23:41):
And I was in it. I was too. think about it. I didn't even think about it.
We're going to go protect American interests overseas.
That still cracks me up. That still cracks me up. But I think what's happening
is a lot of people are waking up to the truth. And that's really the part.
I think that's the exciting part for me on this is that, you know,
you know, we're all looking at this as we're losing and we're not, we're not losing.

(24:04):
We're actually discussing this and we're confronting them. And now they're getting
exposed and they have to do ridiculous things like this.
Now, Now, of course, the article is still bad because it's going to influence people in a way.
But look how desperate they are. Look how they couldn't even have someone to
put their name on this. Is that right, Laura?
Well, the practice with Harvard Law Review forever has been that student notes are anonymous.

(24:28):
Well, I mean, right. But the fact is they wanted it as a note,
though. That's the point. So no one had to put their name to it.
But only students can write notes, and they probably don't accept articles from
students. Who knows? And I mean, who really knows? I mean, who really knows
what's going on? We don't know.
And even if it's a student writing the note, well, if your advisor is telling
you what to write, who really wrote it, right?

(24:50):
So this is how we take, they can't put in, they really won't put their name to it.
No one's willing to put their name to it. I understand it's a student note,
but why is it in a student note and not an article, right?
Well, it's convenient. Actually, my understanding is doing just a little bit of research on this.
My understanding is that the students who are proud of their notes will let

(25:12):
it be known that a particular note was there.
He let his I think he had a note that was unattributed. And then he said,
oh, that's my note. I think he was one who said, oh, yeah, I have a note.
So, yeah, you're right about that. So no one wants to own up to this one. Huh? Hmm.
Amazing. Amazing. I think a lot. Well, I think people would want to own up to it.

(25:34):
I mean, the basic problem is that we, you know, as we agree,
we've got a prestigious law journal basically perpetuating and reinforcing lies.
Coupled, of course, with the unwillingness to, you know, publish a response.
I mean, I wonder if, you know, in addition to anything else here that it would

(25:56):
be worth trying, you know, just circulating generally, I mean,
which I think the blog post at seat does, but.
People have got to understand the role that these institutions play in this,
right? Are there other parts of the article?
John, you made me think of something because on yesterday's podcast,
we were talking about more and how there might be some potential good news in there.

(26:19):
And we were mentioning about how the decision left open the door to say,
well, look, the IC tax is creating a phony disposition that never occurs.
It's creating this phony. So there's really no realization. It's a fake realization
that the exit tax imposes.
And we were mentioning yesterday how, hey, look, the decision of Moore could

(26:39):
actually somebody could actually prevail on a claim that the exit tax is unconstitutional.
And so it's interesting. Right. It's interesting. Moore's released.
We have this note to say, hey, look at these people. They're really this.
Right. They're really they're trying to color that perception of the jurist
mind of what all these people are this. And so to either to to to demonize today,

(27:01):
I mean, the whole intent here is to demonize the elimination of the exit tax.
That's the entire point of this. And isn't that interesting?
And the timing of it really interesting.
We just I just have a note from Karen. Apparently, she's identified who did write the note.
Is that right? Yeah. All you have to do is Google the title.
Oh, really? And you get his LinkedIn post saying, my final piece of student writing. There it is.

(27:30):
Is his name Alexander Johnson?
There he is. Alexander Johnson. Oh, let me follow him.
I'm following you. Let's see. Hey, would you like to be a guest?
Would you like to be a guest on my podcast to discuss?
Anyways. us where are you typing this anthony on linkedin oh okay is he uh graduated

(27:54):
from harvard he is uh harvard law school third.
It's hard to believe i have less than three months left on the journal so
i guess that means i don't know what that means and this was four months
ago he posted it so yeah it looks like that means he's graduated that means
he is a graduate so let's see here let me just put a link to this uh yeah right

(28:19):
on i would love a spirited decision and maybe i should post uh let's see here,
Oh, yeah, he's all ready for his impressive.
Oh, wow. Yeah. So there it is. He is proud about he is proud about this So where
do you think he's gonna go work?
Right where let's see here. We'll follow so i'm gonna follow him and i'll see

(28:40):
you know Where's where where he's gonna
get the next job somewhere in the government. I assume I you know what?
Are you studying for the bar right now? I'm i'm just gonna oh my state department
state You know, we gotta forgot.
I don't know. We we should have we should have a betting pool where he's going to be working next.
Depending on his loans he might not be able to afford that
well you know that's kind of the thing about you know

(29:03):
these schools you know they they happen you know it's funny who really
goes to these schools it's it's not you know it's it's not as they're a little
elite they're a little elite believe it or not now of course you know they they
grab a handful of others but you know for the most part it's like 92 pretty
elite so you know i bet he's doing okay i bet he can go now and be in the government.

(29:24):
And now he's got all his friends and family. Now I have someone in the government
to help him out. I mean, wouldn't you know that?
So we'll see if he, we'll see if they, if they, man, they, wow.
They all look alike, by the way. I'm just looking at the, all his associates.
They all have the same picture. It looks like they all the same photographer. Interesting.
Anyway, back to our podcast, back to the podcast. Thank you.

(29:47):
So Laura, continuing on.
What other things would you like to add in terms of factual problems or other?
Well, you know, I think my response to this note was focused on the note's introduction
and on how it basically maligns overseas Americans.

(30:11):
I did not. And how, you know,
the fact that the author did this meant that they they really missed a big opportunity
instead of basically wasting their
time defending the constitutional constitutionality of the Edson Act.
Why? Why? Why? Someone would a law student would want to do that.

(30:31):
I don't know what what what they could have been doing.
Well i mean really why well as a
law student why would you want to do you you really you know
who's right the people with all the power that's the people we want yeah there
you go i'm a bold law student those in power are right well don't forget everybody

(30:54):
don't forget that the article was written in the context of the more thing that's
where i was going yes this This is where I'm going. It was poisoning his mind, right?
It was, yes. I guess they maybe wanted to have some sort of commentary on more
as if there wasn't enough commentary out there on more.
I mean, God knows, you know, not enough people have written about more.

(31:16):
And so they had to add their own two cents on it.
And so, you know, what I say is, you know, they really missed,
as far as I can tell, this is the only either article or note in the Harvard
Law Review that talks about the exit tax.
If there is another one, I couldn't find it.
And so here is this, it's hard, even as a law student and writing a note,

(31:40):
it's hard to get your note accepted in the law review.
Most of the notes that are submitted aren't published. And so,
you know, you have this golden opportunity to, in Harvard Law Review,
is this golden opportunity to cover this subject it has not yet covered.
And this is how they squander that opportunity.
You know, what they really could have done was look at what's really going on

(32:03):
with this exit tax, and they just completely ignored it, and instead decided
to do something that nobody needed done, which was defend the constitutionality of the exit tax.
And I think here, yes, that John has something to say, especially now that the
Moore decision has come out on just, you know, how easy it is to defend the

(32:24):
constitutionality of the Inquiry Act.
So I would, at this point, probably turn the conversation back to John,
where presumably a second response could be written now to this Harvard Law
Review note that actually addresses the question of the constitutionality of the Inquiry Act.
Right I think there's a couple of points That I would make here First of all it seems to me.

(32:50):
That, I mean, this is very, very obvious, that basically in the world of law
schools, academics generally, and tax academics specifically,
it's pretty clear that they regarded the more, the issue and more,
that is whether, you know, you have to have income realization and taxes.

(33:12):
They almost regarded that as a direct frontal assault on truth,
justice, and the American way.
You know the whole concept of
it right and i think that's very very clear all you have to
do is look at you know club tax prop etc and i
i think that what may have been going on with this note is that it wasn't so

(33:33):
much about the exit tax but you know the exit tax applies to people who are
deemed to be very very unpopular in the united states and so i think that this
was a backhanded way saying that, you know, oh my God,
you know, what this issue in Moore is really about is.
You know, rewarding, you know, horrible people, et cetera, et cetera.

(33:56):
So that's what I think it actually was.
I mean, it's pretty obvious that, I mean, we're not here to talk about the exit
tax, more of the factual misrepresentation of the article, but anybody who understands
the exit tax would have very,
very little difficulty pointing out that, you know, this person doesn't understand
the exit tax as well. I think that's clear.

(34:19):
Actually, that's why I think his job probably will be at the Department of Justice.
That's where I come from. Well, that's possible.
But we're now in a position where, you know, we talked about this yesterday
on Anthony's podcast that interestingly,
the result of the decision is that the constitutionality of the exit tax is,
I think, very, very much in doubt precisely because of the decision and more.

(34:43):
And, you know, know what that means for an article
like this i don't know but i think what it does do
is demonstrates that not only was
the note written on sort of faulty factual
assumptions but you know the legal analysis of it was you know obviously not
so great either right yeah hard to argue with that yes you know yesterday you

(35:10):
know i'm sort of a recipient of in life of all things relating to the exit tax, etc.
I received another couple things from
people talking about the doubtful constitutionality of 877A post-Moore.
So I think that this is a wonderful opportunity to get this thing challenged,

(35:30):
and I think that the challenge should roll out as quickly as reasonably possible.
But what to do about the broader context of things like the Harvard Law law
review having sort of a larger megaphone in the world, right?
You know, get their point of view out. What to do about that?
Yeah. Well, I doubt it.

(35:53):
I'm trying to think of a reason why, but is this note actionable in defamation?
Now, I think if we were able to get to the truth of the matter,
I think we would see a whole bunch of problems with where this note developed.
Might have some problems with that, but you're telling people,
I mean, essentially everybody who's renouncing, you're not calling someone by name.

(36:16):
So I guess here's your problem is like, who did you specifically defame is the issue.
So I'm not sure if that would really go anywhere. I think really the only way
to get the larger megaphone is to continue to do what we're doing,
to continue to do what they're doing.
These articles that they write are so terrible, they can't be shared organically.
They can only be promoted from a top, but people really don't want to read them

(36:39):
because they're so terrible.
And so what we need to beat them with is actual truth, actual organic truth,
and that's why our community is so important to get together and share their real stories.
I mean, the surveys that Laura does are so powerful to blow away their narratives

(36:59):
and you just can rely on those.
And that's why we always want to encourage people to make sure you're filling out the surveys.
These are really, really helpful so we can fight back with the truth.
And, you know, like we know, you know, I know, you know, and we put a lot of
real stories out there about people forced to renounce U.S. citizenship.
And it really does happen.
I think it's might be a good moment for Laura to jump in and explain the survey.

(37:23):
Well, yes, we are conducting a new survey. The response that we prepared,
I prepared for this Harvard Law Review note, cites data and testimony from the
survey that we did in 2020, 2021.
But at this moment, we're conducting a new survey.
There's details and a link to the survey on the SEAT website, seatnow.org.

(37:47):
If you are either a current or former American living outside the United States,
please participate in the survey.
Strongly encouraged to participate. And again, you can get the link.
I mean, we put the link when you post this online, we can put it in the description,
John, link to the survey, but also it's on the SEAT website.
Site absolutely absolutely right and

(38:09):
i think it's important to tell people what seat me what seat
it is stop extraterritorial american
text right it's a
group that has been yeah i wonder you know i wonder given that the purpose of
this podcast is to you know call attention to the in fact the factual inaccuracies

(38:29):
in this harvard law review article a full disclosure okay the three of the the
four participants in this podcast are founding members of SEED, right?
Yes, yes. And the response that I wrote to this Harvard Law Review article,
it's on the SEAT website.
I disclosed it's now a SEAT working paper. That's how you can find it and read it.

(38:50):
But if anybody's, you know, to the extent that people are listening to this
podcast, I think it's important to make clear, all right, that three of the
four participants are founding members.
And certainly, you know, Anthony Parent through his IRS medic podcast is logically aligned. line.
I had another thought that I'd like to throw out about the article generally,

(39:13):
and I'd be interested in your comments.
I agree fully with everybody's general criticisms of the article,
but I think there's a broader problem with this.
And that is, I mean, look, in fairness, anything written about U.S.
Taxation is very, very difficult to understand.

(39:34):
And if If nothing else, the Moore case demonstrated the difficulty of trying
to understand the constitutional basis of U.S. taxation, etc.
Where I'm going with this is that for 95% of humanity,
if they read that article, the only thing they could possibly understand from

(39:57):
the article is that Americans are
renouncing citizenship to avoid taxes or something. That's the only thing.
That any normal person could get out of
that article now let's just
be you know to to separate something here you know like
let's say let's say that you're in in the uk and you

(40:18):
you want to get out of uk taxes what do you do you move
pay tax wherever you live but right right
but but you just move right if you want
to get out of uk taxes you just get on an airplane
and move now hey wherever you're going you might have to
right there but you know so so it's
like why why do these other countries in this world have this um streamlined

(40:39):
um renunciation procedure why why renunciation you get to keep yourself right
why do they keep what right why do you why do you get to keep your citizenship
and eliminate your taxation you get to do both things in all these countries
and the us doesn't allow you to do that and here here we are here we are we
want to we want to fight for,
the American way here, right?

(41:01):
We're going to fight tooth and nail for the American way. You leave us.
How dare you? How dare you not say we're awesome?
Oh, my God, you don't believe us? You don't value us? I mean, it's...
The other thing to note is a lot of these countries do have departure taxes.
Okay. Right? And so when you move out of Australia, for example,

(41:22):
if you're wealthy and have...
Investments in shares or mutual funds and
stuff you're you will you pay
tax on the on the accrued capital gains as of the
date you leave okay okay and this
is this is true whether you're an australian citizen or not
but i don't matter whether you're a citizen when you move out of

(41:43):
australia but it only applies to managed
fund shares other personal property
type things that not real property and
not use superannuation ah all right
for the vast majority of australians their
wealth is in their house and their super yeah so most people aren't even going

(42:06):
to pay it the other thing is you can defer it so you can say okay i'll earmark
these as the assets i had when i left australia and i'll pay the full gain when
i finally sell them well you know you just
remind me of something you know because i know harvard law and and a lot
of a lot of a lot of supreme court justices they'll they'll
say well look how things are done around the world they always

(42:28):
will look to see how things are done around the world but one area they'll never
look right they'll never look is in the area of taxation this is just all we
don't know what that is we don't we don't we're ignorant we don't what what's
another country you know these experts these experts on international law when
it comes to taxation what's taxation what's that.
The advantage of making it a departure tax is that we're,

(42:51):
Looking at the assets you earned while you were a resident of our country,
not the ones that you're going to earn after you leave.
And if you gain Australian citizenship by descent and are never in Australia,
you're never a tax resident of Australia.

(43:12):
So there's no departure tax to pay, right?
Karen, I have a question for you. It seems to me the way you're describing this,
that all of this really comes about because the U.S. has citizenship taxation
as opposed to... Absolutely. Would that be right?
That's right. And that's why so many Americans are renouncing.

(43:33):
Because they can't handle the compliance, not the tax, they're not paying a
ton of tax, but they can't handle the compliance and the worry that some little
foot vault is going to cost them $10,000 in penalties, right? Right.
I mean, that's what they can't. And, and yeah, they want to set up their business
where they live and they want to set it up.

(43:55):
The best way to set it up for the tax system that they live in is as a corporation.
Well, that's going to add all sorts of compliance if you're still a U S taxpayer, isn't it, Anthony?
The way you describe this, the way you describe somebody who listened to this
conversation, I think they would

(44:16):
understand I think it sort of underscores the principle that the U.S.
Tax code is not primarily about tax it's about enforcing a certain kind of lifestyle There you go.
That's it. That is it. You got it, John. Perfect. So in other words, it's a command control.
When we call this citizenship taxation, isn't what it really is,
is forcing any American citizen, no matter where they live in the world,

(44:41):
to have their life governed by the U.S.? Isn't that what it really is?
Well, it forces them to invest in the U.S., have their retirement accounts in the U.S., etc.
But that's not going to work for the country that they live in.
Because guess what? Other countries have tax laws, too. Other countries don't
want you to invest your money outside of their borders.

(45:02):
No kidding. Unbelievable. In fact, this is a good time for me to sign off because
I'm getting on a call with someone who is contemplating renouncing yet another person.
So I will have to leave you, ladies and gentlemen, to the rest of the podcast
while I talk to this American.
Take care. Thanks, Keith. You know, but I mean, as we sort of wrap this up today,

(45:25):
I mean, what's required to end this so-called citizenship taxation?
I mean, I'm going to throw out. It should be severed entirely from tax status.
Sorry, could you repeat that?
Citizenship should be severed entirely from your tax status. Do you agree, Anthony?

(45:46):
I agree. You know, and we could just follow the example of every other civilized
country in the world. That's all.
We're just, look, you know, they may be marketing sexualism on this one.
Maybe we could just get rid of that one. Maybe, you know, this is not that important.
This isn't, this isn't really our country. We're, we're, we're not the,
the, the tax country of the world.
We're actually a country, but you know, the government is just,

(46:09):
you know, our federal government is about 100% control over our lives.
And the tax code is how they do it. You know, One of the most effective ways
to do it. They have other ways to do it too, but they just want to have us control.
They want us to be slaves without letting us know we're slaves.
But we can see it. We can see how they think about us. Hey, look,
you're leaving the United States. Well, that's an estate tax we're going to

(46:31):
miss out on. How dare you?
How dare you that's our prop you are our property and that
has lost trillions of dollars in revenue right as
as a justice amy barrett cohen uh barrett uh
said uh in her more decision she's bemoaning the
bemoaning like oh well if we if
we get rid of these taxes it's going to cost both the u.s government and the

(46:52):
american people trillions of dollars in in income which which sort of seems
like well wait which one does it cost u.s government takes from us so how can
it cost both of us. I don't understand that one. It's a little bit out there.
Maybe we just need, and I think that really the reasonable solution to all this
is we just need to ban every Ivy League graduate from any public employment.

(47:14):
And I think we'll have a much better place there. I think we'll have a much
better world. That's where I'm looking for.
Laura, question for you, sort of as we come to the end. I mean,
I'm assuming you would agree with banning Ivy League graduates from everything.
I think that that's- reasonable proposal but i'll
try you know what the i'm imagining a world where

(47:35):
it's not that or even the country that's not controlled by
i believe graduates and it it's a really
nice thing to think about is it yeah yeah my
question for you laura is this karen has identified an anthony greed severing
citizenship from tax residency as a solution to this now you know You've got

(47:58):
a lot of experience with being members of various groups,
and you spent, I think, a couple of years.
Was it two or three years? I'm not sure what it was with this IRS tap group or whatever it is.
But my question to you is this.
So if complete severance of citizenship from tax residency is the real solution.

(48:22):
Do you think there's a broad understanding that that is the solution?
And is that what these various groups are proposing as the solution?
What are your thoughts on that?
The various groups are not proposing that as a solution.
They try to convince themselves and other people that they are.
But if you really push them on it, they say, oh, that's completely unrealistic.
We won't get that. Or they genuinely don't want it. One of those two.

(48:45):
And so they are going for what they call small win instead.
Could you give me an example or two of what you mean by that?
For example, combining the FBAR and FATCA declaration.
For example, making it or exempting some sort of a recognition or exemption

(49:08):
of foreign retirement payments.
Making your tax return from overseas simpler to file.
Not having to file if your income is under a certain amount.
What I'm hearing from you, Laura,
is that the people who are not advocating for severing citizenship from tax

(49:29):
residency are really advocating for trying to propose solutions that just makes
a horrible situation somewhat less uncomfortable for people. Is that right?
Somewhat less uncomfortable for some people, not everybody. And for some of
the time, not all of the time but yeah well now it's interesting you put it
that way so let me ask two questions here as we come to the end first of all

(49:52):
would everybody on this podcast agree,
that if citizenship is completely severed from tax residency in other words
u.s citizens who live outside the united states are not governed by the u.s
internal revenue code that that would
solve the problems of all people all the time under all circumstances.

(50:14):
Would everybody agree with that?
Yes, and I would say, I know that this goes without saying for us,
but for people who are listening to this for whom it might not be so obvious,
we're clearly not talking about U.S. source income.
No one's arguing that the United States should not tax U.S. source income. Oh, I am. I am.
Well, okay. Well, in fact, in fact. The income tax is a complete lie. Well, okay.

(50:40):
That's a more general conversation. Yeah, yeah, yeah.
I can keep quiet for that. So everybody, staying focused here,
would you agree that the only practical meaning,
right, that citizenship taxation really has is that, you know, one,
of course, that the United States governs the lives of people who don't live in the United States,

(51:02):
but they do it in such a way that they impose direct taxation on people who
do not live in the United States on income sources that are unrelated to the
United States. Would you agree with that?
Yeah, John, I agree 100%. And here's another problem with that,
because we have the worldwide taxing jurisdiction of the United States government,

(51:23):
which, you know, just invented wherever, however, however, it decided to do that.
But the other companion that we have is we have states.
We have states that also believe they have worldwide taxing jurisdiction and then tax accordingly.
And so I'm still trying to figure out, I was like, well, how does a state,
you know, how does a state have the legal authority to do that?
And they'll say, well, we just base it on your federal AGI. That's all we do. too.

(51:44):
Well, your federal AGI is based on your global income.
So the problems, it creates problems all around. You're having people,
states are taxing people who don't live there, right? Isn't that amazing?
Isn't that amazing? The states and the federal, they're together on this one.
So I think that's just something that bear in mind. Now, of course,
with states, it's a problem you
can get out of. If you domicile in South Dakota, that's a way to do it.

(52:08):
California, Maryland, some states might fight you a little bit on it,
but there is a solution to it at least. But it does bear something that when
you think about how does a state get the right to tax someone on their worldwide income?
Well, they just like the US government, they do it, right?
Hey, tax will ask questions later, right?

(52:28):
So, Laura, your point was that where a severing citizenship from tax returns
solves the problem of all people all the time under all circumstances.
What I think you said was that, you know, these sort of incremental improvements
to the prison of citizenship taxation at best would help some people some of

(52:49):
the time under some circumstances.
Would that be right? Mm-hmm. Yeah.
So my question to you is, why is it so difficult to get broad based?
I mean, why would somebody not want to support ending citizenship taxation?
Why would anybody not want to support that?

(53:11):
Well, I think there's different responses to that.
And probably at any given moment with any given person, you might be,
you know, their response might might differ.
But I think what you have going on is you have a certain number of people who
who like things the way they are or mostly like things the way they are.
They're afraid of what the change might be.

(53:32):
You know, those people maybe have some sort of special benefits under under
a tax treaty that most other Americans overseas don't have.
For example, right. For example, France. I mean, to be clear.
Yes. Yeah. Yeah. Sure. That's probably the most obvious example.
And you also have people who simply haven't yet experienced the problems the way other people have.

(53:59):
And so they, you know, they just are kind of like, what's the big deal?
And then I think you you also have people who will say that's just not realistic.
You're just not going to get that. You're not going to get, you know,
a full severing of citizenship. Congress will never agree.

(54:19):
Yeah, Congress will never agree. And so it's never going to happen.
And so let's go after things that are more realistic.
And this, I think, at the moment is the prevailing attitude.
I think I think there are there are still people who are afraid of what citizenship
based or, you know, getting rid of citizenship based taxation might mean for
them, particularly, you know, if they've got some sort of U.S.

(54:43):
Source income that's suddenly going to be taxed as a as a non-resident alien.
But I think the prevailing, my
sense is the prevailing issue right now is the sense of we can't get it.
We can't get, you know, real RBT.
And so let's just go for these smaller things.
We have members, you know, we have groups, we have members. We have to go back

(55:07):
to our members and show we accomplished something.
And so let's go for these small things that we can at least show them we've
accomplished something.
Now, the next question I want to ask you, and this is, you know,
clearly, clearly, you know, looking for an opinion, okay, but how many of you or who here thinks that.

(55:27):
The goal of anything other than severing citizenship from tax
residency is really a worthwhile goal i think
it muddies the waters yeah no and the problem
the problem with all these carve-outs when you're creating carve-outs okay here's
an exception for so-and-so that they don't have to do this here's an exception
for so-and-so who doesn't you go through this you're actually making the code
more complicated when you're adding in carve-outs you're actually saying you

(55:51):
know so so who would say hey you know what the solution to the solution to all the
problems of citizenship-based taxation is to make the tax code more complicated, right?
No one would say that, but when you're saying you want to have these carve-outs,
that's exactly what you're going to do because now what's going to happen is,
well, maybe you had that exemption one year, but something changed and you weren't paying attention.

(56:12):
And now this year you do have to do the thing. And now you're wide open for that penalty exposure.
Hey, you, you didn't do what you were supposed to do. So I think the last thing,
the last thing we add, we need is any more complications in the U S tax code.
What we need is delete, delete, delete.
I think the other problem is, yeah, you go to Congress and say,

(56:34):
okay, combine the F bar and FATCA reporting.
And the next year you come to Congress and you said, well, we want you to do
this. And they go, well, we already fixed it for you. We did that already.
Why are you still having problems right like combining those right like well
now we're not right well we gave you we gave you what you wanted you wanted
it simpler we gave you what you wanted now.

(56:57):
Right, exactly. And John, to your question before, why somebody would agree
to their own circumstances of their own demise?
And I think of my own story, and then the great Charles Adams,
his book, his book for good and for evil.
I'm not sure how close your copy is mine. I don't know where mine is.
But again, for me, the chapter I would not read, the one chapter I would not

(57:22):
read until I just had to was the chapter on U.S. taxation.
I was fine learning about how every other country used taxes to abuse its citizens
and all these terrible things.
But the one I didn't want to confront was my own country, because if I did, then what do I have to do?
Is there some action I will need to take?
Because you're so much better off being in the bubble of rah, rah, rah.

(57:44):
George Washington was a great guy. Abraham Lincoln was a great guy.
Instead of looking at the truth you're better off doing
that because when you look at the truth now what do you
do now what do you do because you know and
the whole thing is you want to identify like i like to identify with
the victors right well hey george washington was a great guy so was abraham
lincoln right like lee we're america first right and you didn't want to look

(58:07):
at your whole basis for it you didn't want to look at actually what was there
because it destroys this mythology this uh intellectual superstructure that
we have around our lives that keeps us together.
Because once you see the truth, now it's scary.
It's really scary to see the truth because all the assumptions you've had about
the value systems you've made in your own life, the values you have in your

(58:30):
own life, you have to confront.
And so it is much easier to hang onto your tribe.
It's much easier to hang on your tribe. And really most people won't examine
it until they have to, But that's the great thing about citizenship-based taxation. It's so terrible.
And I loved Keith, you know, Keith and I, I don't know how much Keith and I
would agree politically 10 years ago, but to hear him say the things that he

(58:53):
did, I was like, amen, brother, amen, brother, Keith, you got it.
You got it. So, I mean, that's really, what's fascinating.
Look how terrible, look, we won't even know each other.
We won't even know each other. If it wasn't for the terrorism,
citizenship based taxation, look, look at us now.
So I think that's really what it's out. And so why people are hanging on to
their tribalism is fear.

(59:15):
It's really fair fear because the truth is frightening.
It will set you free, but it is going to scare the living crap out of you on its way.
So I think that's really what it's about is people don't want to know the truth.
You don't want to know it. You just keep going, keep going and keep your blinders on.
Hey, everything's great. Everything's great everywhere.

(59:36):
So I think that's really what it's about, but it's been a great awakening for
me and I think for a lot of others as well.
I think there's a larger discussion around what Anthony just said about what
the United States is and what it does on a world scale, not just with respect to taxation.
Right. Yeah, exactly. Yeah, absolutely, Laura.

(59:58):
That's a discussion for another day. I would just add one more thing in response to Dara's question.
The problem I have with going after these smaller things is that the list is never ending.
And, you know, you can go after one thing and there's a list of 50 other things
that people are going to be saying, well, what about this? And what about this?

(01:00:20):
What about this? What about this?
We have very limited resources.
We're a very small number of people. You know, I'm talking about all of all
the Americans, all the groups that are working on these issues.
We're very small in number. we have almost no
resources and if we spend it all
we can't do everything if we

(01:00:42):
spend all of our time and resources on these small things and we're not spending
our time and resources on the big thing we're not asking for the big thing we
are never going to get the big thing never because we have just spent all of
our time resources and political capital on this on one or two small
thing to me that's a complete waste complete

(01:01:04):
waste and certainly not how i'm interested
in spending my own resources yeah laura you
know i think you're absolutely right but combining you know the thoughts of
karen and laura it seems to me that and you may you may have implied this okay
but i think it needs to be said directly that the worst possible thing that these groups groups,

(01:01:30):
lobbyists, whatever you may want to call amateur lobbyists can do,
is not make clear what the solution of the problem is.
I mean, it's one thing to go in and say, we need citizenship severed from tax
residency, but for the moment, could you help us with this smaller issue?
That's an entirely different thing from going in and not making it clear the

(01:01:54):
problem is that citizenship means to be severed from tax residency,
and asking for all of these smaller things.
So, you know, I think that, I think you implied this earlier,
that I think that there's a real danger that a lot of these groups may very
well reinforce citizenship taxation to the point where there's no chance of it ever being changed.

(01:02:15):
Thoughts on that? Unfortunately, you're right.
What can I say? It's unbelievable to me. The solution is severing citizenship from tax breaks.
It's unbelievable to me that that's the one thing they won't ask for.
Incredible stuff. That's how the solution will become, renounce your citizenship.
Well, you know, I don't think, you know, when you combine the Moore decision

(01:02:38):
this week, right, when you combine that with some of the other things that are
going on, you know, The general throwing in the towel,
you know, these groups saying now we're not going to ask for severing citizenship from tax residency.
I really think the time has come for those who can renounce.
I think they better get moving with it.
But, OK, interesting discussion today.

(01:03:02):
Laura, why don't I invite you to sort of do a bit of a wrap up here and send,
you know, your response to the Harvard Law Review note. with what really prompted this podcast.
So I invite you to sort of summarize your final thoughts.
Well, just that, you know, we need to be vigilant about these types of things

(01:03:23):
and that certainly we need to call people out when they need to be called out.
I would invite people who've listened this far to go ahead and have a look at the response.
You can find it on the SEAT website. You'll find a link to it.
And also please participate in SEAT's survey.
Survey also you can find that on the seat website

(01:03:44):
s-e-a-t now.org and
thanks to john and karen and anthony and keith for
talking about this i'm glad we were able to all right karen any final any final
thoughts not really i mean the the harvard law review note that we've been discussing
just It just really shows us what Americans in the U.S.

(01:04:10):
Think of people who decide to make their life outside the U.S.
Well, I think it shows you what Harvard Law says. That they don't think of it.
They think that the only reason you would leave the U.S. is to avoid U.S.
Tax, which is ridiculous. kill us.
Okay, I mean, I think to put it very, very generally, there's absolutely no

(01:04:32):
understanding of the factual context here, right? Okay. Anthony?
Final thoughts? Well, I would say it's interesting. I said, you know,
I think we know where the author is going to work because he obviously doesn't
care about private clients, right?
If this is something you're doing, you're saying, hey, look,
you guys are just trying to scam the system by expatriating.

(01:04:55):
So I think the tone of the article shows exactly what he's grooming himself
for, where he wants to be.
And that's sort of sad. That's sort of sad. So I think it's just something to
think about why a young Harvard lawyer would immediately torch private practice.

(01:05:15):
Like, no, I don't want to do private practice. And that's essentially what he's done.
I mean, could you imagine hiring this guy as your tax attorney or whatever,
or an attorney? He's going to favor the government.
He already told you that. And he's fine letting everyone know that.
And so I think that's really sad. I don't think he understood what he did here.
That I think he was, you know, he's naive and young and look,

(01:05:38):
I was in law school too, and you do things for approval. It's kind of a nasty system.
But that's really a sad thing that he doesn't even consider actual clients and
actual people to be part of people who he could ever help.
There's only one entity, I think, that he's looking to help out. And that's pretty sad.

(01:05:58):
Yeah, I think, in closing, my final point would be that, I mean,
obviously, you know, the problem of disappearing in the Harvard Law School is evident.
But the article itself is, I wouldn't call it incoherent, but I would say that
it's a very, very difficult subject matter, making the broader theme of the
article very, very difficult to understand,

(01:06:20):
you know, which I think makes these sort of factual misrepresentations that people can understand.
That is, people renounce citizenship to somehow avoid taxation,
you know, even more dangerous.
All right. Well, thank you all very much. This has been an interesting discussion,
and we will no doubt be continuing this discussion in further podcasts.

(01:06:43):
All right, great. Thanks so much. Thanks, John. Thank you. Thanks, Laura and Anthony.