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News:News Commentary
November 29, 2021 - Participants Include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
Two Solitudes = U.S. State Department and U.S. Treasury
Virginia and I continue our podcasts in which we clarify myths and misconceptions about renouncing US citizenship. This podcast emphasizes the difference between the immigration/nationality aspects of renunciation vs. the tax aspects of renunciation.
Although tax compliance is NOT required to renounce US citizenship, renunciation without tax compliance does have tax consequences.
This podcast focuses on more areas of misunderstanding and confusion ...
Renouncing US citizenship triggers issues under each of:
1. The Immigration and Nationality Act under 349(a); and
2. The Internal Revenue Code under sections under 7701(a)(50), 877A and 877, 2801
To put it simply: There are a lot of moving parts.
In this podcast Virginia La Torre Jeker and John Richardson continue our discussion including:
Immigration/Nationality Issues:
- is tax compliance required to be allowed to renounce US citizenship?
- what are the legal requirements to renounce US citizenship?
- is a second citizenship required in order to renounce?
Tax Issues:
- what is a covered expatriate?
- what does it mean to be subject to the US 877A expatriation tax?
- how are different kinds of assets treated for the purposes of expatriation?
- pensions vs. property ...
- ways of avoiding covered expatriate status (gifts, pre-renunciation sales, etc.)
- what about post-renunciation gifts from covered expatriates to US citizens?
- Relief Procedures For Former Citizens
Previous podcasts with Virginia include:
How Does Renunciation Of US Citizenship Affect Entitlement To US Social Security Payments?
Is It True That Renouncing US Citizenship Will Result In Being Barred From The United States?
Insights and Solutions Into The Problem Of US Citizenship Or Holding A Green Card
SEAT Working Paper Series - Extraterritorial Taxation #15 - Taxing in Respect of Rights
Canada's New Capital Gains Tax And Navigating Wealth Management Strategies in Canada
SEAT Working Paper Series - Extraterritorial Taxation #14 - Revenue Neutrality Makes No Sense
The Life And Times Of Nova Scotia's Atlantica Party - With Ryan Smth
SEAT Working Paper Series - Extraterritorial Taxation #13 - Other Countries Have A Duty To Act
The US Tax Treaty Saving Clause As A Vehicle To Tax Residents Of Other Countries On Non-US Income
SEAT Working Paper Series - Extraterritorial Taxation #12: It's Not About Paying Taxes
Insights into the Intertwining of Politics and the Law in Ontario's Justice System
SEAT Working Paper Series - Extraterritorial Taxation #11: Deference or Constitutionalization?
SEAT Working Paper Series - Extraterritorial Taxation #10: Violating Human Rights
Insights on Boosting Immunity to fight the common cold with Health Coach David Coutts
David McKeegan's Journey with Greenback Tax Services
SEAT Working Papers Series - Extraterritorial Taxation #9: Forcible Destruction Of Citizenship
SEAT Working Papers Series - Extraterritorial Taxation #8: More Violations of Equal Protection
Coach Coutts - Leave The Democracy To US!
Canada's Justice System: A Deep Dive With The Founders of Compassionate Justice Canada
SEAT Working Papers Series - Extraterritorial Taxation #7: Unlocking the Complexities and Discrimination of Citizenship Taxation Laws
Catching Up With Amy From Sydney - Unraveling US Taxation and Voting for Expatriates
SEAT Working Papers Series - Extraterritorial Taxation #6: No Compelling Governmental Interest
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