PREP Podcaster - ”Success Favours The PREPared Mind”
News:News Commentary
February 9, 2021 - Participants Include:
Dr. Karen Alpert - @FixTheTaxTreaty
Tim Smyth - @Tpsmyth01
John Richardson - @Expatriationlaw
Internal Revenue Code 6039G requires US Treasury to publish the names of US citizens who relinquish US citizenship. Some refer to the list as the "Name and Shame" list, while others call it the "Liberty List".
6039G in relevant part includes:
"Notwithstanding any other provision of law, not later than 30 days after the close of each calendar quarter, the Secretary shall publish in the Federal Register the name of each individual losing United States citizenship (within the meaning of section 877(a) or 877A) with respect to whom the Secretary receives information under the preceding sentence during such quarter."
Surprisingly there is wide disagreement about:
- exactly which individuals are required to be named on the list (all relinquishers, "covered expatriates" only, Green Card holders?)
- the accuracy of the list (how well does it correlate with the actual numbers of relinquishers)
- the reasons individuals relinquish US citizenship (political or to escape the US tax an/or regulatory net)
In this podcast we discuss: What does the list purport to represent and how accurate is the list?
SEAT Working Papers Series - Extraterritorial Taxation #5: Refuting the Rationales
To Renounce Or NOT To Renounce: The Problem is HOW To Make The Renunciation Decision
Moore v. United States -December 5, 2023 - The Argument Before The Court
December 5, 2023: Debriefing The Moore Case - A View From Inside The Courtroom - It’s All In The Snyder Report
SEAT Working Papers Series - Extraterritorial Taxation #4: Why Nothing Changes
The Ron Wyden ”Billionaires Tax Act” - The Future Of US Taxation And Income Realization
Twas The Night Before Moore - SEAT Members Discuss What They Expect In Moore Hearing
SEAT Working Papers Series -Extraterritorial Taxation #3: Education and Advocacy
SEAT Working Papers Series -Extraterritorial Taxation #2: How It Is Experienced
Coach Coutts - Leave The Purpose To US!
SEAT Working Papers Series - Extraterritorial Taxation #1: How It Has Evolved
John Alan Pod - Episode 214: Taxation And Americans Abroad
Responding To The Bittner FBAR Decision - The IRS ”Resets” The Penalty Principles
A US Social Security Primer With Katrina Haynes of HaynesHelp
Why The 3.8% NIIT (”Net Investment Income Tax”) Is Especially Unjust For Americans Abroad
Meeting Anthony Parent: The Man Behind IRS Medic
Should Digital Nomads Living Outside The USA Keep All Their Financial Accounts In The USA?
Gifts And Bequests From A Former US Person: Avoiding A 40% Tax Payable By The Recipient
Mi’Azhikwan: First Nation Status As Citizenship - Losing And Gaining Citizenship
Latin American Opportunities: Whether Retiring Or Seeking A Digital Nomad Visa
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