PREP Podcaster - ”Success Favours The PREPared Mind”

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

November 20, 2025 12 mins

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 t...

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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

 

 

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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 tha...

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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...

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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-comm...

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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 ...

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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 (FBA...

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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, fiv...

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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 expl...

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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 internatio...

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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-bas...

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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-b...

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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 finan...

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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 t...

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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....

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