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."

August 8, 2025 - Speakers Include: Alex Ugorji - @AlexUgorji David Bindel - @DavidBindelTx Mat Farel - @MatFarel Parviz Malakouti - @ParvizMalakouti John Richardson - @ExpatriationLaw AI Description:   "Join Citizenship and Immigration Attorney Parviz Malakouti in a deep dive into the complexities surrounding citizenship renunciation. In this insightful episode, recorded on August 8th, Malakouti, alongside experts Alex Ugorji and John Richardson, explore the intricate web of laws and obligations that trap individuals in unwanted citizenships, highlighting the often-overlooked complications of extraterritorial obligations. The discussion spans various geopolitical contexts, from the U.S. to Argentina, and delves into the unforeseen difficulties of acquiring and relinquishing multiple citizenships in today's interconnected world. Listen as experts debate the potential threats and strategic considerations for individuals seeking mobility and freedom in an era where citizenship laws are under increasing scrutiny. Discover why more citizenships might not always offer more freedom, the looming threat of legal obligations that transcend borders, and why relinquishing citizenship can be a daunting task. Whether you're an aspiring global citizen or just curious about international law, this episode offers valuable insights into a rapidly evolving landscape."

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

July 30, 2025 - Speakers Include: Dr. Laura Snyder - @TAPInternation Parviz Malakouti - @ParvizMalakouti BitCoin Backpacker - @BackPacker_BTC John Richardson - @ExpatriationLaw On July 17, 2025 Representative Hurd of Colorado introduced Bill H.R. 4501. The purposes of the bill would include the exemption of U.S. citizen Pope Leo from taxation under the Internal Revenue Code. Congressman Hurd’s bill is discussed here: https://citizenshipsolutions.ca/2025/07/29/colorado-congressman-jeff-hurd-recognizes-problems-of-u-s-citizenship-taxation/ This was an interesting and lively discussion which considered how Americans abroad might make use of H.R. 4501 in their mission to end U.S. citizenship taxation.

July 24, 2025 This is a recording of a discussion an “ X.com Space” hosted by U.S. immigration Parviz Malakouti. I (John Richardson) contributed to the discussion. When exactly does a U.S. citizen relinquish U.S. citizenship?   X.com Handles: Parviz Malakouti - @ParvizMalakouti John Richardson - @ExpatriationLaw

July 21, 2025 This is a recording of a discussion an “ X.com Space” hosted by U.S. immigration Parviz Malakouti. I (John Richardson) contributed to the discussion. X.com Handles Parviz Malakouti - @ParvizMalakouti John Richardson - @ExpatriationLaw

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