September 18, 2026 - Participants include:

Virginia La Torre Jeker - @VLJeker

John Richardson - @ExpatriationLaw

Today Virginia and John discussed the penalty situation of a U.S. citizen who had always lived in Mexico. He received gifts from his Mexican father and failed to notify the IRS of the gifts. This is a common and very expensive (from a penalty perspective) mistake.

What follows is the ai generated description of the podcast.

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 "John Richardson and tax lawyer Virginia La Torre-Jeker dissect the recent Antonio Cesar Fuentes case involving Form 3520 foreign gift reporting. The IRS assessed a 25% penalty - under IRC 6039F - after Mr. Fuentes failed to report gifts from his non‑U.S. father that exceeded the $100,000 threshold, sparking a $90,000 penalty, refund litigation, and administrative confusion.

The conversation explains how filing suit can transfer settlement authority from the IRS to the Department of Justice (26 U.S.C. §7122), create forum issues for U.S. citizens living abroad (they are presumed to live in Washington, DC) , and reveal clashes between IRS and DOJ procedures.

The episode highlights the complexity of international gift rules, the severe penalties for noncompliance, and the need for careful reporting."

September 15, 2026

Dave Keating - @DaveKeating - Brussels based journalist and author of "The Owned Continent" 

John Richardson - @Expatriationlaw - Toronto, Canada based expatriation lawyer

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About Dave Keating:

About today's podcast:

John Richardson interviews Dave Keating about his book The Owned Continent and his argument that Europe is deeply dependent on the United States militarily, economically, and culturally. Keating traces his own move to Europe, explains how English and U.S. infrastructure shape European life, and calls for a stronger, more federal EU to reclaim real sovereignty.

The conversation covers Brexit’s consequences, Canada‑EU ties and Mark Carney’s role, the danger of U.S. control over payments and cloud systems, and practical steps Europe must take—cultural, economic and political—to free itself from American dominance.

September 2, 2026 - The Christensen and Bruyea cases and how the court interpreted the French and Canadian tax treaties allow the double taxation of by the United States of non-U.S. source investment income!

Overview - The 30,000 view

This episode examines the August 31, 2026 Federal Circuit decision in Christensen v. United States and related Canadian cases, showing how Congress placed the 3.8% Net Investment Income Tax in a separate chapter of the Internal Revenue Code to block foreign tax credits and effectively override treaty relief.

We explain the legal text, the court's reasoning, the practical impact on U.S. citizens living in France and Canada, and the broader implications for double taxation, expat finances, and the reliability of international tax treaties.

The provided sources detail a significant legal dispute regarding whether U.S. tax treaties with France and Canada allow citizens to claim foreign tax credits against the Net Investment Income Tax (NIIT). While lower courts initially issued conflicting rulings, the U.S. Court of Appeals for the Federal Circuit ultimately determined that the Internal Revenue Code prohibits such offsets. The court clarified that the "U.S. Law Limitation" within these treaties ensures that credit eligibility remains governed by domestic statutes, which do not currently recognize the NIIT as a creditable tax. Consequently, Americans residing in these countries face double taxation on the same investment income because the treaty provisions do not operate independently of U.S. law. Expert commentary from legal scholars and blog posts further emphasize that this interpretation prioritizes statutory restrictions over the general treaty goal of eliminating double taxation. This legal outcome confirms that specific passive income taxes remain a unique burden for expatriates despite bilateral agreements.

August 27, 2026 - Lost and Found: Canada's Citizenship Shockwave

Purpose of this podcast AI generated podcast:

The question: You may be a Canadian citizen if you were born to a Canadian citizen. But, how we tell whether your ancestor was a Canadian citizen?

The analysis: This episode traces the century‑long evolution of Canadian nationality law — from imperial British subject status through exclusionary rules, the 1947 Citizenship Act, and later reforms — culminating in Bill C‑3 (Dec 15, 2025) which retroactively restored citizenship for millions.

It explains the practical impact: who became Canadian (or lost citizenship), the documentary hurdles to prove status, the huge application backlog, and why some people may need to renounce newly acquired citizenship to comply with their home country’s laws.

A simplified summary: The four phases of evolution of Canadian citizenship law:

1. The 1947 Canadian Citizenship Act, which established Canadian citizenship independent of British subject status;

2. The 1977 Citizenship Act, a brand-new framework that permitted dual citizenship for the first time but did not retroactively restore status to those who had previously lost it by naturalizing abroad, while successfully eliminating gender-based discrimination to allow citizenship transmission through mothers;

3. The 2009 amendments, which retroactively restored citizenship to individuals who had lost it under former rules (including naturalization in the U.S. or elsewhere), while simultaneously instituting a strict 'first-generation limit' for passing citizenship to children born abroad; and

4. Bill C-3 (effective December 15, 2025), which dismantled that first-generation cutoff, granting citizenship to individuals born abroad to a Canadian parent prior to that date, while establishing a new 'substantial connection' residency test for future generations born abroad. Crucially, the 2014 and 2017 amendments to the Citizenship Act had little bearing on these issues, as they focused strictly on the naturalization requirements for permanent residents living inside Canada.

August 15, 2026 - AI generated podcast based on a blog post by John Richardson.

"Canada's new citizenship by descent law - a search for proof more than a search for truth"

This podcast is based on the second post in my series exploring Canada's Bill C-3. Specifically it focuses on how to prove the entitlement to a certificate of Canadian citizenship.

https://citizenshipsolutions.ca/2026/08/13/canadian-citizenship-by-descent-a-search-for-proof/

In general, this podcast explores how Bill C-3 transforms Canadian citizenship into an administrative paper chase, abruptly suspending certificates and forcing descendants to prove identity with precise historical records.

AI generated description about the blog post:

"This article highlights the complexities of claiming Canadian citizenship by descent under updated legal frameworks like Bill C-3. The author emphasizes that while individuals may technically be citizens, the burden of proof lies with the applicant to provide definitive documentation, such as ancestral birth and marriage records. For those born after December 2025, requirements are even stricter, necessitating proof of a parent’s physical presence in Canada for at least 1,095 days. The text features various professional perspectives, including genealogists and immigration consultants, to illustrate the creative methods needed to verify lineage. Ultimately, the source serves as a guide for "Lost Canadians" and dual citizens to navigate the rigorous administrative search for historical evidence. It concludes that securing a Certificate of Canadian Citizenship is a demanding task that requires significant preparation and authoritative proof."

August 11, 2026 - AI Generated Podcast based on the following blog post at CitizenshipSolutions.ca

What does Canada's Bill C-3 actually say? How does citizenship by descent now operate in Canada?

https://citizenshipsolutions.ca/2026/08/08/understanding-the-citizenship-by-descent-provisions-of-bill-c-3-of-the-canada-citizenship-act/

The post includes the following:

"The purpose of this post is narrow. It is to explain how the new “citizenship by descent rules” follow from the text of Section 3(1) of The Canada Citizenship Act.

https://laws-lois.justice.gc.ca/eng/acts/C-29/page-1.html#docCont

Bill C-3 – Canada’s new citizenship law – Effective December 15, 2025

I am going to be honest. I find it very difficult to read the Canada Citizenship Act and make sense of it. I understand what the commentators say that it says. That’s great. But I feel more comfortable if I can understand the legislation, parse the legislation and understand how the sections fit together.

Bottom line: If somebody asks you:

Q. Where in the Canada Citizenship Act does it specifically say that, if a child is born outside of Canada, after December 14, 2025, to a parent who was a Canadian citizen and that Canadian citizen parent was also born outside of Canada, then that parent is required to have 1095 days of physical presence in Canada prior to the child’s birth in order to transmit citizenship to the child?

A. Well, you better be able to provide an answer."

AI Description of the blog post:

"This article details the updated citizenship by descent regulations introduced by Bill C-3 in the Canada Citizenship Act, which becomes effective on December 15, 2025. The legislation creates a significant opportunity for individuals born abroad to gain Canadian citizenship, specifically by removing previous restrictions for those born before the new start date. However, for those born outside the country on or after this date, a physical presence requirement is introduced, necessitating that the Canadian parent lived in Canada for at least 1,095 days before the birth. The text highlights that while individuals born to naturalized citizens or those born in Canada remain citizens, others must carefully document their parents' residency history. By parsing specific legal sections, the author explains how these amendments impact generational citizenship and the ability to pass it down as a family heritage. Ultimately, the source serves as a practical guide for expatriates and dual citizens to navigate the complexities of evolving Canadian nationality laws."

July 24, 2026 - A Podcast Based On A July 17, 2025 John Richardson Presentation About Canada's Bill C-3

Canada's Bill C-3 became law on December 15, 2025. The Bill clarifies who - if born outside of Canada to a Canadian citizen parent IS a Canadian citizen. Note that this is NOT a fast track to naturalization.

About Canadian citizenship:

1. Those born in Canada or naturalized as Canadian citizens ARE Canadian citizens.

2. Those born outside of Canada to a parent who was either born in Canada or naturalized is a Canadian citizen IS a Canadian citizen.

3. Those born outside of Canadian to a Canadian citizen parent who was born outside of Canada to a "first generation Canadian" IS a Canadian citizen.

4. Those born outside of Canada to A Canadian citizen parent who was a "second generation Canadian" is based on whether you were born before December 15, 2025 or after December 15, 2025:

- If born before December 15, 2025 you ARE a Canadian citizen if your parent, grand parent, great grand parent, etc. was a Canadian citizen;

- If born after December 15, 2025 you ARE a Canadian citizen if your parent,  was a Canadian when you were born and had 1095 days of physical presence in Canada before your birth.

"First generation Canadian" = A Canadian citizen who was born outside of Canada to to a Canadian citizen who was born outside of Canada to a parent who was born or naturalized in Canada.

"Second generation Canadian" = A Canadian citizen was was born outside of Canada to a Canadian citizen who was born outside of Canada to a Canadian citizen parent who was born outside of Canada to a parent who was also born outside of Canada.

Sound confusing? This is explained in the podcast.

"This podcast examines the significant legal shifts introduced by Canada’s Bill C-3, which restores and expands citizenship by descent for individuals born abroad. The legislation is presented as a vital tool for U.S. citizens to achieve dual nationality, potentially allowing them to navigate restrictive tax regimes and secure mobility rights. Beyond the legal definitions of birthright and naturalization, the source details the practical benefits of Canadian status, including universal healthcare and simplified entry into the United Kingdom. However, obtaining a citizenship certificate requires rigorous documentation and a clear ancestral lineage to prove eligibility under the new rules. For those who qualify, the author frames this status as a valuable family legacy that facilitates residency in Canada without the need for a traditional retirement visa. While the bill offers many advantages, the text also notes the process for renunciation for those who wish to avoid the obligations of dual citizenship."

July 31, 2026 - PFIC Odyssey Part 2

The explanatory text of the 1986 PFIC rules is found here:

https://citizenshipsolutions.ca/wp-content/uploads/2023/12/jcs-10-87-PFIC-section.pdf

https://citizenshipsolutions.ca/2023/12/19/general-explanation-of-the-1986-tax-reform-act-pfic-edition/

AI Generated:

"This episode is a deep dive into PFICs (Passive Foreign Investment Companies) and how a technical area of U.S. tax law can unexpectedly punish everyday investors, heirs, startups, and new immigrants. It explains what triggers PFIC status, the punitive Section 1291 default, alternative elections like QEF and mark-to-market, and real-life examples of how the rules can devastate savings.

The episode also reviews proposed reforms from Monica Gianni’s "PFICs Gone Wild" — practical fixes to protect legitimate businesses and modern investors — and leaves listeners with a warning about the unseen risks of global investing today."

Thoughts:

The "Microsoft" example is compelling. It's okay for deferral to take place as long as it is NOT within a foreign corporation. But, those investing outside the USA will pay the price!

July 30, 2026 - The PFIC At Age 40 - What were the PFIC rules understood in 1986?

The explanatory text of the 1986 PFIC rules is found here:

https://citizenshipsolutions.ca/wp-content/uploads/2023/12/jcs-10-87-PFIC-section.pdf

https://citizenshipsolutions.ca/2023/12/19/general-explanation-of-the-1986-tax-reform-act-pfic-edition/

The podcast is based on the description in 1986 of what Congress was intending to do. This is a great help in understanding the PFIC regime as the rules are described in the Internal Revenue Code which is described as:

"Interest On Tax Deferral"

https://www.law.cornell.edu/uscode/text/26/1291

AI generated description of this podcast:

"This episode explains how the Tax Reform Act of 1986 created the Passive Foreign Investment Company (PFIC) rules to stop U.S. investors from using offshore funds to defer taxes. It covers the income and asset tests that replaced ownership thresholds, and why lawmakers built severe penalties to neutralize offshore tax advantages.

It also outlines the enforcement mechanics — the throwback tax and interest charges — and the voluntary Qualified Electing Fund (QEF) alternative that forces current taxation. Finally, it discusses the law's broad reach and why ordinary investors today can accidentally trigger these complex rules."

Of course in 2026 it's clear that the PFIC rules make retirement planning for Americans abroad exceedingly difficult.

July 21, 2026 - Participants include:

Dan Hughes - @RadikalHughes

John Richardson - @ExpatriationLaw

Host John Richardson speaks with Dan Hughes about Canada’s Bill C-3 and Dan’s personal journey discovering he may be a Canadian by descent. Dan describes how he found his Canadian ancestors on Ancestry.com, hired a genealogist, and traveled across Michigan to collect certified birth, marriage and death records to prove his claim to the Immigration, Refugees and Citizenship Canada (IRCC).

The episode explains the step-by-step proof process (primary and secondary documents, census and baptismal records), the urgency around filing due to application backlogs and possible legal changes, and the implications for future generations and family identity.