Space 25 - April 12, 2025: The 1980 Carter Report On Citizenship Taxation: Nothing Has Changed In 45 Years

April 12, 2025 - Participants include:

 

Dr. Suzanne de Treville - @SdeTreville

Tim Smyth - @TpSmyth01

Brad - @InvertedFragility

Brent Vanderbrook - @Vanderbrook

John Richardson - @ExpatriationLaw

 

Note: This podcast is a recording of an "X Spaces" discussion. The actual audio does not start until approximately the two minute mark.

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Introduction …

In 1980 President Jimmy Carter filed a report on the topic of "U.S. Law Affecting Americans Living and Working Abroad".

The Carter report was …

“A legislative effort by Senator George McGovern required the President to conduct a thorough study of laws governing U.S. citizens abroad. This report by President Jimmy Carter was the first under that law - a painstaking review of the many legal provisions affecting U.S. citizens residing abroad. Issues include loss of citizenship by children born abroad, income tax, social security, veterans benefits and many other matters - and very little has changed since this report was written, so this is still a valuable legal guide for any American taking up foreign employment or residence.”

The book is available here.

It is a fascinating report in terms of its content. In addition, to the content it reveals the impressive work done by "American Citizens Abroad" in its formative years. Significantly, many of the problems that exist today were identified in 1980. Very little has changed for the better.

 

Significantly the report is based on a world BEFORE:

• FBAR enforcement AKA The Obama/Biden “FBAR Fundraiser”

• the creation of the PFIC rules in 1986 (Reagan tax reform)

• Obama/Biden FATCA in 2010

• the Clinton Treasury Foreign Trust rules of 1996

• the Clinton Entity classification regulations of 1996

• the Obama OVDI/OVDP programs beginning in 2009

• Trump administration Transition Tax/GILTI rules of 2017

Note that EVERY ONE of these things is the result of U.S. citizenship taxation.

The ONLY solution is a complete separation/severance of citizenship from tax residency. Hate to say it, but there is NO OTHER option.

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On April 12, 2025 Dr. Suzanne de Treville led a discussion about the Carter report. Her discussion specifically referenced a presentation and spreadsheet which are at the following two links:

https://docs.google.com/presentation/d/1_fN0iCzcBhftbiemFYEm9B7dQsCQp9O8bV7D0a70JV8/edit?usp=sharing

https://docs.google.com/spreadsheets/d/1tCwz7RM2Uc1RV8o0rY7BBprVv3_357TSAJ-D4-eZicM/edit?usp=sharing

 

In addition, Dr. de Treville referenced the earlier work of AARO, which is documented in the following post.

 

https://citizenshipsolutions.ca/2024/01/21/the-unknown-ambassadors-a-saga-of-citizenship-phyllis-michaux/