PREP Podcaster - ”Success Favours The PREPared Mind”
Discussion about current events, culture, independent candidates, business, education, travel, death and taxes, global mobility, citizenship and residence by investment options, Americans abroad, FATCA, CRS, U.S. citizenship renunciation, Green Card abandonment, citizenship taxation, PFIC, GILTI, foreign trusts, I-407 and more ...
Episodes
https://x.com/i/spaces/1aKbdbMQDnRJX?s=20
Participants include:
Dr. Laura Snyder - @TAPInternation
Dr. Suzanne deTreville - @SdeTreville
John Richardson - @ExpatriationLaw
"This transcript features a discussion regarding a significant State Department notice that officially lowered the fee for renouncing US citizenship from $2,350 to $450. While the par...
March 13, 2026 - A "Deep Dive"
Conversation generated from a podcast about the Isaac Brock Society blog post discussing the reduction in the fee for a CLN from $2350 to $450.
Description:
"This text reports on a significant reduction in the administrative fee for obtaining a Certificate of Loss of Nation...
A second and different AI generated podcast about the Bruyea/Christensen NIIT appeals ... based on a conversation between:
John Richardson - @Expatriationlaw
Tim Smyth - @TpSymth01
On March 3, 2026, the Federal Circuit heard back-to-back appeals (Bruyea — Canada and Christensen — France) over whether foreign taxes paid by Americans abroad can be credited against the 3.8% Net Investment Income Tax (NIIT). The core fight is over ...
March 7, 2026 - AI generated based on:
"State of Play on Voting by Americans Abroad"
https://aaro.org/images/pdf/STATE_OF_PLAY_2026_FEB_16_FINAL.pdf
This 2026 white paper from the Association of Americans Resident Overseas (AARO) details escalating legal and legislative challenges to the voting rights of U.S. citizens living abroad. The report highlights federal bills like the SAVE and MEGA Acts, which threaten to mandate in...
March 4, 2026 - AI Generated podcast based on my X Space with Tim Smyth.
"Deep dive into two appeals heard March 3, 2026, at the U.S. Court of Appeals for the Federal Circuit challenging whether the Net Investment Income Tax (NIIT) can be offset by foreign tax credits despite a domestic statute that separates the NIIT from Chapter 1 credits.
Using firsthand notes from courtroom observers, this episode explains the legal conflict ...
March 3, 2026 - Oral argument in the United States Court of Appeal in Christensen v. United States
AI generated description ...
"This episode covers the oral argument in Christensen v. United States, examining whether Article 24 of the U.S.–France tax treaty permits a foreign tax credit against U.S. tax beyond the Chapter 1 limitation and whether the Chapter 2A net investment income tax is creditable.
Central issues include w...
March 3, 2026 - Oral argument in the United States Court Of Appeals In Bruyea ...
AI generated description of the hearing:
"This episode covers oral arguments in a case about whether the U.S.–Canada tax treaty allows a foreign tax credit to be applied against the U.S. net investment income tax (Section 1411), which Congress placed outside Chapter 1 of the Internal Revenue Code.
Advocates debate whether the treaty phrase "in acc...
March 2, 2026 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @ExpatriationLaw
______________________________________
Introduction and purpose ...
Entitlement to U.S. Social Security (including spousal and survivor benefits) after expatriation has always been difficult. During the months of January and February 2026 U.S. tax lawyer Virginia La Torre Jeker did a "deep dive" into how expatriation impa...
February 20, 2026 - AI Analysis of the Supreme Court decision striking down Trump's tariffs ...
The Supreme Court said President Trump's tariffs policies under IEEPA are unconstitutional, dealing a major blow to the president's signature economic policy. Chief Justice John Roberts wrote the 6-3 opinion. Justices Clarence Thomas, Samuel Alito and Brett Kavanaugh
You can read the actual Supreme Court decision here:
February 18, 2026 - Based on a presentation created for an IRS Medic podcast.
AI generated description of the podcast ....
"This episode unpacks John Richardson’s February 18, 2026 presentation on "Deemed Income in the Netherlands," explaining how governments are shifting from taxing realized gains to taxing unrealized, deemed income. Using the Dutch Box 3 example (36% tax on deemed returns), the episode explores the liquidity ...
February 6, 2026 - Participants include:
February 6, 2026 - Participants include:
Professor Hank Adler - Chapman University
John Richardson - Toronto, Canada - @ExpatriationLaw
On January 29, 2026 Tax Notes published the following article by Professor Adler:
"When An Income Tax Is Not A Tax On Income"
The following podcast discusses Professor Adler's article ...
AI generated description:
"John Richardson interviews Professor Hank Adler about the Moore case a...
January 29, 2026 - Participants include:
Dr. Laura Snyder - @TAPInternation
Dr. Suzanne deTrevile - @SdeTreville
Tim Smyth - @TpSymth01
John Richardson @ExpatriationLaw
Background:
This week the Taxpayer Advocate released its 2025 report.
Significantly the report included "Taxpayers Living Abroad" as one of the most serious problem areas encountered by taxpayers. The report is remarkable in its recognition of both the c...
November 13, 2025 - Participants include:
Parviz Malakouti - @ParvizMalakouti
John Richardson - @ExpatriationLaw
_________________________________________
Introduction and description:
The second Trump administration has caused and will continue to cause a reawakening of a discussion on the meaning of U.S. citizenship. What does it mean? How strong is it? What rights does it include? How can it be lost?
We are also living in a ti...
January 13, 2026 - "Global Mobility" - Participants include
Ryan Herche - Global Mobility Consultant
John Richardson - @ExpatriationLaw
This is my second podcast with Ryan Herche. On August 4, 2022 he was my guest on a podcast where we discussed the possibility of France adopting citizenship taxation. You can listen to that podcast here:
https://prep.podbean.com/e/yes-france-has-considered-adopting-citizenship-taxation-a-discussi...
January 9, 2025 - Based on the Amicus Brief filed by Professors Rosenbloom and Shaheen in support of the argument that the Canada U.S. tax treaty DOES require the United States to allow a credit against the Net Investment Income Tax ("NIIT") for taxes paid to Canada.
"This episode examines Bruyea v. United States, focusing on whether a U.S. citizen living in Canada can use Canadian tax credits against the U.S. Net Investment Inco...
January 5, 2026: AI Generated podcast based on Attorney General Benjamin Civiletti's 1979 argument in the International Court when the U.S. Embassy was seized in Iran.
Mr. Civiletti's statement to the court is here:
https://www.justice.gov/sites/default/files/ag/legacy/2011/08/23/12-10-1979.pdf
Here is the AI description of the statement ...
"On December 10, 1979, the United States asked the International Court of Justice for...
January 2, 2026 - AI generated podcast from upcoming post written by John Richardson at The Isaac Brock Society.
"In this episode of The Deep Dive we unpack the three-year delay in reducing the Certificate of Loss of Nationality (CLN) fee and what that delay reveals about the U.S. government's treatment of Americans living abroad.
Using public comments, legal precedent, and a breakdown of three exit taxes—the CLN fee, the 877A ex...
December 29, 2025 - AI Generated
This is an AI generated podcast which describes the Rule Making Notice which appeared in the Federal Register on October 2, 2023. This notice describes the Rule Making undertaken by the State Department to reduce the fee to process a Certificate of Loss of Nationality from $2350 to $450 (where it was in 2014).
A link to the Federal Register is:
December 8, 2025 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @ExpatriationLaw
"Hosts John Richardson and Virginia La Torre Jeker unpack Senator Moreno's proposed bill to eliminate dual citizenship and the practical effects it could have if enacted.
They explain the tax risks, including the exit tax and "covered expatriate" rules, how Social Security payments and benefits for expatriates coul...
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