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 urgent provisional measures to end the illegal seizure and imprisonment of American diplomats in Tehran. Led by Attorney General Benjamin Civiletti, the U.S. framed the plea as an emergency injunction grounded in law, not politics. The episode traces the four-pronged legal strategy—Vienna Conventions on Diplomatic and Consular Relations, the 1973 convention on Crimes Against Internationally Protected Persons, and the 1955 U.S.–Iran Treaty of Amity—and shows how the case sought to protect individual lives while defending the foundations of the international diplomatic system."  

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 expatriation tax, and the 2801 covered gift tax—we show how citizenship taxation and reporting requirements can coerce people into renouncing and even punish their heirs. We also examine the constitutional questions raised by Afroyim v. Rusk, the bureaucratic path of the fee reduction, and why lowering the administrative fee alone may not address the deeper systemic problems driving Americans to give up their citizenship."

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: https://www.govinfo.gov/content/pkg/FR-2023-10-02/pdf/2023-21559.pdf     "This episode contrasts two federal actions from the October 2, 2023 Federal Register: an FAA airworthiness directive forcing U.S. operators of certain older Airbus A300 variants to implement new structural maintenance limits within 90 days to address fatigue and reduced structural integrity, and a State Department proposed rule cutting the Certificate of Loss of Nationality fee from $2,350 to $450 to reduce financial deterrence, costing the Treasury about $8.8 million annually. It explores how safety imperatives can make cost irrelevant while policy choices can justify deliberate subsidies, and asks where the government should draw the line between technical necessity and political priorities."

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 could be affected, special concerns for Native American tribes, and possible diplomatic complications. The conversation highlights legal uncertainties, real-life consequences for dual nationals and Americans abroad, and the likelihood of ongoing debate and pushback."

December 3, 2025 - Participants include:   Virginia La Torre Jeker - @VLJeker   John Richardson - @ExpatriationLaw   This podcast is based on Virginia's Forbes article - "Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship" - which appeared on December 3, 2025.   AI generated description: "Host John Richardson and U.S. tax lawyer Virginia La Torre Jeker  discuss the "Exclusive Citizenship Act of 2025", a proposed law that would force dual citizens to renounce foreign citizenship or lose U.S. citizenship within a year, and bar future dual nationality. The episode reviews Supreme Court precedent (Afroyim v. Rusk and Vance v. Terrazas), constitutional concerns about involuntary expatriation, who would be affected (naturalized citizens, children with dual nationality, spouses, long-term expatriates), and potentially severe tax consequences including the exit tax."

December 3, 2025 - Participants include:   Parviz Malakouti - @ParvizMalakouti   Brent Vanderbrook - @Vanderbrook   John Richardson - @ExpatriationLaw   This podcast of an X.com "Space" that took place on December 3, 2025. Here it is:   https://x.com/ParvizMalakouti/status/1995905374034297232     "Citizenship and Immigration Attorney Parviz Malakouti breaks down Ohio Senator Bernie Moreno's "Exclusive Citizenship Act of 2025", a bill proposing a blanket prohibition on U.S. dual citizenship. The episode explains key provisions — how foreign citizenship is defined, automatic relinquishment after acquiring another nationality, a one-year deadline for existing dual citizens to renounce one citizenship, and proposed enforcement and record-keeping measures. Malakouki and guests discuss the bill's constitutional and legal weaknesses, possible tax consequences (including triggering the exit tax), who would be most affected (those who naturalized as citizens of another country, hidden dual citizens, and Americans abroad), and broader privacy and policy implications. They assess the bill's low immediate chance of passage but warn of its dangerous precedent and call for continued public attention and advocacy."

November 20, 2025 - An AI generated podcast from a John Richardson presentation with IRS Medic.   AI generated summary:   "This episode unpacks FBAR—from its 1970 origins under the Bank Secrecy Act to today’s wide reporting net that catches signing authority, beneficial ownership, and many routine foreign accounts. We explain the filing threshold, how FBAR differs from IRS information forms, the discretionary power Treasury holds to exempt Americans abroad, and why civil and criminal penalties can be severe enough to ruin lives or push people to renounce citizenship."

November 13, 2025 - Participants include:   Parviz Malakouti - @ParvizMalakouti Brent Vanderbook - @Vanderbrook John Richardson - @ExpatriationLaw   Information, reason and the outline of the "Space" is here:   https://x.com/ParvizMalakouti/status/1986483363931431382    

November 11, 2025   Citizenship Apartheid - Paper by Professor Dimitry Kochenov   https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4680018   This podcast is based on Professor Kochenov's thought provoking paper.   AI description: "In this episode we unpack a provocative argument: modern citizenship functions as a form of global apartheid, sorting people by birthright into zones of opportunity and exclusion. The sources argue that passports operate as a blood-based aristocracy, granting vast privileges to a minority while trapping the majority behind steep visa walls. We trace the system’s colonial roots, explore compensatory citizenship and regional intercitizenships, and ask whether freedom of movement—not voting—is the fundamental right at stake. The episode challenges the rhetoric of universal rights by showing how nationality often determines life chances."

November 10, 2025 - Warren Buffet letter to Berkshire shareholders. A "treasure trove"of advice ...   https://www.berkshirehathaway.com/news/nov1025.pdf   Here is the AI description:   "In his November 10, 2025 Thanksgiving message, Warren Buffett, 95, disclosed converting 1,800 A shares into 2.7 million B shares and immediately earmarking them for four family foundations: 1.5M to the Susan Thompson Buffett Foundation and 400K each to the Sherwood, Howard G. Buffett and Novo foundations. He explained the practical reason for moving to B shares and the timing, citing his age and his children’s trusteeship window. Buffett also confirmed Greg Abel as Berkshire Hathaway’s CEO effective year-end and said he will step back from public-facing duties while continuing his Thanksgiving letter tradition. The message mixes this major corporate and philanthropic news with memoir-style stories about Omaha, gratitude for those who supported him, and examples of how luck and place shaped his life. He offered sober business warnings — especially about CEO impairment and the unintended effects of pay disclosure — and a philosophical closing: accept limits, acknowledge luck, improve steadily, and live so your obituary reflects kindness and integrity."

November 9, 2025 - Participants include:   Virginia La Torre Jeker - @VLJeker   John Richardson - @ExpatriationLaw   Prologue:   Virginia recently published a post discussing the issues generated by a U.S. citizen married to a nonresident alien with the couple living in a non-US "community property jurisdiction". You are invited to read the post here: https://us-tax.org/2025/11/07/a-complicated-u-s-tax-life-foreign-spouses-and-community-property/ What follows is an AI generated description of our podcast.   "John Richardson and Virginia La Torre Jeker discuss the risks U.S. citizens face when married (or considering marriage) in jurisdictions with community property rules. The episode explains how foreign marital property laws can cause a U.S. spouse to be treated as owning half of assets, triggering reporting requirements (Form 8938 and FBAR), income inclusion, and harsh PFIC rules. The hosts advise listeners to investigate local marital property regimes, consider prenuptial or postnuptial agreements, map asset histories, and obtain both U.S. tax and local legal advice to avoid unexpected tax and estate consequences.

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."