This AI generated podcast is based on a SEAT post announcing our latest article published in Tax Notes. The article explains how President Trump’s pledge to end the double taxation of Americans abroad can be achieved by the U.S. waiving it’s “saving clause” rights under the treaty.

https://seatnow.org/2025/10/06/a-simple-and-unilateral-treaty-fix-for-citizenship-taxation-richardson-snyder-and-alpert/

To test your knowledge of the concepts, check out the flashcards at:

https://notebooklm.google.com/notebook/69edd0bf-f0b3-4855-b544-7f93b17485ea?artifactId=906feeb7-4ee8-40c7-b26e-a3edb8112701

Unilateral Treaty Fix for Citizenship Taxation

1 source

The source argues for a unilateral treaty fix to mitigate the effects of U.S. citizenship taxation on Americans living abroad, particularly focusing on how this causes double taxation. The authors contend that the U.S. Treasury can achieve this by simply declining to use the “saving clause” in tax treaties, which currently reserves the U.S.’s right to tax its citizens as residents regardless of treaty provisions. If the Treasury refrains from invoking this clause, U.S. citizens could be treated as “treaty nonresidents” like Green Card holders, allowing them to benefit from the treaty’s residency “tie breaker” rules. This administrative action is proposed as a way for the President to fulfill a pledge to end the double taxation of expats without requiring legislative or formal regulatory changes. The text explains that the current system, supercharged by the saving clause, forces U.S. citizens abroad into dual tax residency, leading to worldwide taxation and complexity, often on non-U.S. source income.

Tim Symthe - @TpSmyth01

David Bindel - @DavidBindelTx

Dr. Suzanne DeTreville - @SDeTreville

John Richardson - Expatriation Law

This podcast is largely based on a post that appeared on the SEAT site at:

https://seatnow.org/2025/10/06/a-simple-and-unilateral-treaty-fix-for-citizenship-taxation-richardson-snyder-and-alpert/

“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.”

This is an AI generated podcast from a presentation I created. The AI description of the presentation is:

Renouncing US Citizenship: Reasons, Rules, and Risks

1 source

“The provided document, primarily authored by John Richardson, offers a comprehensive guide to the decision and process of renouncing U.S. citizenship, focusing heavily on the complex tax implications for expatriates and long-term Green Card holders. The text outlines the statutory requirements for relinquishing nationality, noting that the act must be performed with the intent of abandoning U.S. nationality before a consular officer. A major theme is the potential for double taxation on worldwide income and assets that U.S. citizens living abroad face, which often prompts the consideration of renunciation, particularly as individuals age and accumulate more foreign assets. Significant attention is dedicated to the financial hurdles, especially the “Covered Expatriate” status which triggers the 877A Exit Tax and the associated wealth thresholds and tax compliance requirements. The guide also touches on the practical good and bad news related to income tax, estate tax, and immigration rights following renunciation, including the loss of the right to enter or live in the USA, alongside strategies for avoiding Covered Expatriate status through planning and family considerations.”

I thought it would be interesting to have AI create a podcast of Professor Edward Zelinsky’s 2024 paper titled:

Defending U.S. Citizenship-Based Taxation in Theory and in Practice: An Essay on Fiscal Citizenship in a FATCA World

Here is the AI description:

“Defending Citizenship-Based Taxation in a FATCA World

1 source

The provided text is an academic essay arguing in favor of the United States' citizenship-based taxation of its citizens living abroad, justifying it through the concept of "fiscal citizenship," which asserts that membership in a political community entails a duty of tax support. The author contends that the U.S. system is more administratively efficient and less unique or harsh than critics claim, pointing out that other nations like Canada, Australia, and the U.K. achieve similar worldwide taxation results via complex residence and domicile rules. Furthermore, the essay discusses how U.S. tax treaties and the Foreign Account Tax Compliance Act (FATCA) mitigate some problems for overseas citizens and argues that the generous Section 911 exclusion for foreign earned income makes the U.S. system uniquely taxpayer-friendly compared to other nations. Ultimately, the piece frames the debate as a fundamental disagreement over whether U.S. citizenship is a "one-way street" granting rights without corresponding duties.”

The following AI Generated podcast is based on a presentation that I delivered 10 years ago in London, UK. Not much has changed.

Here is the AI generated description of the presentation:

Sacred Trust: Counselling Through U.S. Citizenship Trauma Abroad

1 source

The provided text, "Sacred Trust: Counselling Clients Through the “Trauma of U.S. Citizenship Abroad” in a FATCAesque World," by John Richardson, outlines the significant challenges faced by U.S. citizens living abroad due to the Foreign Account Tax Compliance Act (FATCA). It details how financial institutions worldwide are identifying individuals with U.S. indicia, leading to many discovering they are considered U.S. persons and are therefore subject to U.S. taxation. The document emphasizes the emotional and financial "trauma" associated with this realization, including the complex decisions regarding renunciation of citizenship and the potential for a hefty "Exit Tax" for "Covered Expatriates." Ultimately, the text highlights the specialized and sensitive counseling required for these individuals, stressing that advisors act as life counselors guiding clients through profound and often life-altering decisions. The source also touches on the negative impact U.S. citizenship abroad has on financial and business opportunities.

4 minutes ago

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.

________________________________________________

Citizenship Taxation: A Flawed Solution for Global Mobility

1 source

The provided text explores citizenship taxation as a potential remedy for the challenges that global mobility and digitalization of work pose to traditional tax systems. It examines how taxation based solely on citizenship aims to prevent tax base erosion by taxing citizens worldwide, regardless of their residence, but argues that this approach is too simplistic and faces significant administrative hurdles, as seen in the United States' experience. The text also highlights how wealthy nations are better equipped to implement such systems unilaterally, potentially exacerbating global disparities, and questions whether multilateral cooperation would genuinely benefit all states equally. Ultimately, it suggests that a combination of citizenship and residence-based taxation might offer a fairer and more effective solution by better aligning tax obligations with actual community membership.

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."

July 30, 2025 - Speakers Include:

Dr. Laura Snyder - @TAPInternation

Parviz Malakouti - @ParvizMalakouti

BitCoin Backpacker - @BitCoinBackpacker

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