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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 ...

  1. 6D AGO

    Supreme Court Slams the Brakes: No Emergency Tariffs for the President

    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: https://citizenshipsolutions.ca/2026/02/20/u-s-supreme-court-strikes-down-trump-tariffs-read-the-decision-here/   "The Supreme Court ruled that the International Emergency Economic Powers Act (IEPA) does not authorize the president to impose broad tariffs, rejecting the administration's attempt to use emergency powers to rewrite trade policy. The decision restores ordinary trade law and returns tariff authority to Congress, raising immediate relief for import prices but leaving open political questions about whether lawmakers will act on long-term trade and emergency powers."

    18 min

  2. FEB 18

    When Paper Profits Become Cash Demands: The Netherlands' 36% Deemed Tax Nightmare

    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 crisis this creates, especially for U.S. citizens living in the Netherlands who face mismatched tax timing and potential double taxation. Richardson examines technical workarounds like PFIC/mark-to-market elections and warns they may not reliably protect taxpayers. He closes with a philosophical plea for simplicity: avoid excessive complexity, prioritize liquidity, and rethink whether accumulating wealth remains an asset when it can force owners into debt or costly compliance."

    15 min

  3. FEB 11

    Tax Treaty vs. Tax Code: Can the IRS Ignore Its Tax Treaty Promise?

    February 6, 2026 - Participants include:   Dr. Suzanne deTrevile - @SdeTreville Tim Smyth - @TpSmyth01 Brent Vanderbrook - @Vanderbrook John Richardson @ExpatriationLaw https://citizenshipsolutions.ca/2026/01/09/bonjour-part-6-rosenbloom-and-shaheen-brief-in-support-of-bruyea/   AI Description:   "This episode examines the legal battle over the Net Investment Income Tax (NIIT) and whether the IRS can deny foreign tax credits by placing the tax in a different chapter of the Internal Revenue Code. It walks through the Christensen (France) and Bruyea  (Canada) cases, the treaty-language arguments, and the upcoming March 3, 2026 appeal. Experts explain why the dispute matters beyond a small revenue amount: it could determine whether U.S. domestic technicalities can override treaty obligations, affecting expats, major corporate taxes, and the credibility of U.S. treaty commitments."

    18 min

  4. FEB 6

    When an Income Tax Isn’t an Income Tax: Unpacking the Moore Case

    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 and a rarely discussed constitutional issue: taxing undistributed foreign earnings using rates tied to a taxpayer's liquidity rather than its income. Adler argues this departs from the 16th Amendment’s promise of an income tax. The conversation also covers retroactivity concerns, potential state-level experiments like California’s proposed wealth tax, and the broader implications for tax policy and constitutional limits."

    27 min

  5. JAN 29

    When Home Taxes Chase You Abroad: Inside the 2025 Taxpayer Advocate Report

    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 compliance problems and the substantive laws impacting Americans abroad. I highly recommend that you read the report. The report includes:     "In short, the current system imposes unnecessary harm on U.S. taxpayers abroad, discouraging compliance and eroding trust in the fairness of the nation’s tax administration. Unless the IRS takes meaningful steps to improve its services, guidance, and systems for these taxpayers, the frustration and fear experienced by Americans abroad will continue to grow, harming not only them but also the integrity of the tax system as a whole."   The report includes the following description of a hypothetical U.S. citizen abroad: “Sue, a U.S. citizen, has lived and worked in Australia for many years after marrying her Australian husband, Sam. As a dual citizen, Sue pays Australian income taxes on her wages but also remains subject to U.S. tax laws. They have been advised their income is always less than the foreign earned income exclusion. They have joint checking and savings accounts in an Australian bank, and on various paydays the combined balance of their joint accounts exceeds $10,000 USD. Sue participates in an Australian superannuation, a compulsory system for retirement savings. Three years ago, she inherited some stock shares from her Australian aunt, which she keeps in the same brokerage house that maintained her aunt’s account. Sue and Sam have not filed a U.S. income tax return or an FBAR. Sue eventually learns that because she is a U.S. citizen she must also file a U.S. tax return to report her Australian income, with Forms 3520, 3520-A, 8938, and 8621 (depending on the investment in the superannuation). They also must electronically file FinCEN Form 114 (FBAR) using FinCEN’s BSA E-Filing system. If they file tax returns, they may owe U.S. taxes and penalties thereon. They would also be subject to foreign trust penalties for failing to disclose Sue’s Australian pension plan, FATCA and FBAR penalties, and possibly foreign gift penalties for failure to disclose her Australian inheritance that is not subject to tax.” It then goes on to detail the unfairness and impossibility of the situation "Sue" finds herself in. The AI description of this podcast is: "The episode reviews the 2025 Taxpayer Advocate report highlighting severe compliance burdens on U.S. citizens living abroad: confusing rules, limited IRS support, harsh penalties, and the damaging effects on retirement, finances, and citizenship decisions. Speakers explain the report’s key examples—FBAR/FATCA filings, exit tax and pension inequities—and discuss how these problems threaten voluntary compliance and call for systemic reform to separate citizenship from taxation."

    1h 8m

  6. JAN 19

    When Voting Cost You Your Passport: The Strange History of Strict Liability and Citizenship and The Benefits of Dual Citizenship

    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 time where there is a heightened awareness of the value of multiple citizenships. What does have dual citizenship mean?  For Americans, the single most important "citizenship case" is Afroyim v. Rusk. While making dual citizenship possible, it also has played a role in creating the tax problems of Americans abroad today. On November 13, 2025 I participated in a "X Space" discussion with Parviz about the Afroyim case. It was a great discussion. You can hear the complete discussion here. The following podcast is a condensed version of the discussion (covering the essential points in a 15 minute version).  Enjoy (if that is possible)! What follows is an AI generated description, which really does not justice to this discussion. ________________________________________ AI generated description: "This episode traces how "strict liability" once let the U.S. revoke citizenship for simple acts like voting, and how the Supreme Court’s Afroyim v. Rusk shifted the rule to require intent to relinquish citizenship. It explains the two-tiered system—14th Amendment birthright citizenship versus statutory citizenship for children born abroad—and explores the modern strategic response: securing dual citizenship to preserve exit options from U.S. tax and bureaucratic obligations. Experts discuss practical steps (documenting births and passports) and the geopolitical urgency to claim alternative citizenships while options remain open."

    17 min

  7. JAN 13

    From Texas Checkpoints to Four Passports: A Family’s Global Mobility Journey

    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-discussion-of-its-report/ Today Ryan returns to discuss that growing interest in global mobility generally. More and more people are realizing the importance of global mobility and the option of having a second (or more) country of residence and/or citizenship. Fascinating discussion with Ryan Herche and why he is pursuing a career in this growing area.   "John Richardson speaks with Ryan Herche about his COVID-era awakening, moving his family to Mexico, obtaining French citizenship by descent, and using birth tourism and remote work to build global mobility. They cover the practical benefits of dual citizenship from birth, U.S. citizenship taxation and exit risks, residency and education strategies, and advice for Americans seeking options and personal sovereignty."

    1h 24m

  8. JAN 9

    Treaty vs. Tax: Can a Canadian Credit Offset the U.S. Net Investment Income Tax?

    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 Income Tax (NIIT), and how a single treaty phrase — “subject to the limitations” — has spawned a major legal dispute. Featuring analysis from treaty negotiator H. David Rosenbloom and Professor Fadi Shaheen, the episode breaks down the government’s Chapter 2A argument, the treaty’s intent to prevent double taxation, and the broader diplomatic and legal stakes of interpreting the U.S.-Canada tax treaty."

    11 min
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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 ...

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