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@citizenshipsolutions
How Canada Pioneered Modern Departure Taxes And The US 877A Exit Tax
Introduction Podcast – A history of Canada's Departure Tax. What is intended to be a "class tax" always becomes a "mass tax". This is full of lots of intrigue and Canadian tax history (even for those not interested in tax).https://t.co/2d2JpmYEYu — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) July 18, 2026 Exit/Departure taxes are imposed when an individual severs tax…
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What To Hold And What NOT To Hold In A Canadian TFSA Or UK ISA
Americans abroad should have a Canadian TFSA or U.K. ISA. But, they need to be very careful about what they hold in them …https://t.co/piBiUCi51h — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) July 8, 2026 What follows is a post that I wrote for the Isaac Brock Society. It has broad application. I thought I would provide it on this blog as well. The Saga Continues – What…
Taxation Makes U.S. Citizenship A Caste System With Or Without Birthright Citizenship
On June 30, 2026 the Supreme Court Of The United States released it’s decision in Trump v. Barbara. The complete decision can be read here: https://www.supremecourt.gov/opinions/25pdf/25-365_4hdj.pdf The 14th Amendment of the U.S. constitution starts with the following language: Section 1 All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens…
IRS Ends "Delinquent FBAR Submission Procedures" Leaving No "Guaranteed Penalty Free Option"
Introduction Podcast – On June 30, 2026 the IRS removed the "Delinquent FBAR Submission Procedures" option from it's site. @VLJeker and @ExpatriationLaw explain why for #Americansabroad who have not filed @InFBARWeTrust, the change creates "uncertain penalty" for (possibly) "uncertain… — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) July 2, 2026 On June 26, 2026 I did a…
December 2011 - IRS FS-2011-13: Information for U.S. Citizens or Dual Citizens Residing Outside the U.S.
Purpose The purpose of this post is to archive the 2011 IRS Fact Sheet for U.S. Citizens or Dual Citizens Living Outside the U.S. The summer of 2011 was a particularly difficult time for U.S. citizens living outside the United States. Many of them were learning about U.S. citizenship taxation and FBAR for the first time. Many made the mistake of entering the IRS 2011 Offshore Voluntary Disclosure…
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The End Of The Board Of Appellate Review And A Tribute To Chairman Alan James
Prologue On July 18, 2017 the Washington Post included a section describing: “Notable Deaths in the Washington, area” Alan James, lawyer, State Dept. officer Alan James, 96, a lawyer who specialized in admiralty law and a State Department officer who served as a delegate to international panels on laws of the sea, died June 13 at a hospital in Bethesda, Md. The cause was heart ailments, said a…
About The Expired U.S. Passport - Is It Proof Of U.S. Citizenship (Yes)? Can It Be Used As A Travel Document (No)?
Introduction There is no such thing as a small citizenship problem. In many instances the only thing worse than being a U.S. citizen is NOT being a U.S. citizen. Many individuals who have never lived in the United States are U.S. citizens. They endure the problems of U.S. citizenship taxation and restricted access to financial accounts (yes, in many instances U.S. citizenship can be a…
AARO To File Amicus Brief To Support Argument That FBAR Penalties May Violate 8th Amendment Prohibition On Excessive Fines
It is important that all #Americansabroad support @AARO in their filing an amicus brief to argue that #FBAR penalties (in certain circumstances) violate the 8th Amendment which prohibits the imposition of excessive fines. See below👎https://t.co/jqgoXnbAaZ — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) April 21, 2026 The AARO brief is for the benefit of ALL Americans…
You Know A Tax System Is Broken When People Fear Tax Compliance As Much As They Fear Noncompliance
When tax compliance is weaponized because of the "status" of an individual there is a risk in attempting compliance and a risk in non-compliance. The undocumented in the USA have a lot in common with US citizens outside the USA. (NYTImes.com gift article)www.nytimes.com/2026/04/14/u… — John Richardson (@expatriationlaw.bsky.social) 2026-04-17T12:52:36.628Z U.S. citizens living outside the United…
President Obama Confirms That Success In American Should Be Determined By Work And NOT By Accident Of Birth!
http://citizenshipsolutions.ca/wp-content/uploads/2026/04/ScreenRecording_04-17-2026-20-09-55_1.mp4 Does he not understand that U.S. citizenship taxation and FATCA penalize Americans based on an “accident of birth”?
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Trump v. Barbara - Ending The "Birth Tourism" Presumption That Birth On U.S. Soil Is A Sufficient Condition For U.S. Citizenship
Prologue On Wednesday April 1, 2026 the Supreme Court of the United States will hear the “Trump v. Barbara” case. This issue is whether birth on U.S. soil is sufficient to confer U.S. citizenship regardless of the legal status of the parents. You can listen to the live argument on the Supreme Court site. It all takes place on Wednesday April 1, 2026 at 10:00 a.m. Eastern time. I will post the…
Some Americans Considering A Move To Canada May Already Be Canadian Citizens
An incredible opportunity for those who qualify for @Can_Citizenship by descent.https://t.co/zqfFgDdJJ4 — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) March 8, 2026 I just got off a call with a Canadian resident who wishes to renounce his U.S. citizenship. He is NOT a naturalized Canadian citizen. Rather he was born in the United States (making him a U.S. citizen) to a…
Bonjour Part 8 - Interpreting The Tax Treaty To Create Double Taxation Instead Of Eliminating Double Taxation
Introduction This is part 8 in a series of posts detailing the evolution of the “Elimination Of Double Taxation” clause in U.S. tax treaties. Some of the posts also discuss the Bruyea and Christensen cases which result in the double taxation of non-U.S. source investment income under the Internal Revenue Code. The first seven posts are found in Appendix B of this post. “Can’t see the forest, but…
AARO White Paper Explains Why The Voting Rights Of Americans Abroad Are Under Attack
Introduction The U.S. constitution does not give U.S. citizens a constitutional right to vote. Rules for and eligibility to vote are granted (or not) on a state by state basis. The voting “rights” of Americans abroad has been the subject of significant advocacy over the years. In January of 2024 I wrote an extensive post detailing the history of AARO’s advocacy in lobbying for voting rights for…
How Expatriation Affects U.S. Social Security Benefits - A Podcast With Virginia La Torre Jeker
#Podcast – @VLJeker and @ExpatriationLaw discuss how expatriation impacts U.S. Social Security benefits.#Citizenshipmatters – not all people are treated the same.https://t.co/vcKWkFh0ph — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) March 2, 2026 Introduction and purpose … Entitlement to U.S. Social Security (including spousal and survivor benefits) after expatriation…
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Becoming A Citizen: For Some It's Letting Go, But For All It's Moving On
February 24, 2026 Honored to attend a Canadian citizenship ceremony today. Congratulations to 121 new Canadian citizens and their families. pic.twitter.com/h2NL9tDhek — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) February 25, 2026 Today was a special day. For me it was special because I was invited to be a guest at the official ceremony of a person taking the oath of…
Justice Warren's Dissent In Perez v. Brownell Supports Right To Renounce Citizenship
Introduction Former U.S. Supreme Court Justice Earl Warren wrote of the importance of citizenship and the meaning of citizenship in his famous 1958 dissent in Perez v. Brownell. I suspect that his dissent may be resurrected in 21st Century citizenship litigation. https://t.co/CuOwCv42hx — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) February 25, 2026 More and more U.S.…