Discussion about current events, culture, independent candidates, business, education, travel, death and taxes, global mobility, citizenship and residence by investment options, Americans abroad, FATCA, CRS, U.S. citizenship renunciation, Green Card abandonment, citizenship taxation, PFIC, GILTI, foreign trusts, I-407 and more ...
PREP Podcaster - ”Success Favours The PREPared Mind”
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5.0(1 reviews)
191 episodes
Updated Weekly
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46
Podcast Authority
BetaFairBased on show quality, social media presence, reviews, charts, and more
Quality80
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YouTube0
Engagement32
Podcast Overview
Discussion about current events, culture, independent candidates, business, education, travel, death and taxes, global mobility, citizenship and residence by investment options, Americans abroad, FATCA, CRS, U.S. citizenship renunciation, Green Card abandonment, citizenship taxation, PFIC, GILTI, foreign trusts, I-407 and more ...
Language
🇺🇲
Publishing Since
1/8/2023
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46
Podcast Authority
BetaFairBased on show quality, social media presence, reviews, charts, and more
Quality80
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Engagement32
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Recent Episodes
July 30, 2026
When Congress Caught the Offshore Game: Born in 1986 - The PFIC Is Now 40
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
How I Found Out I Was a 'Lost Canadian' — From Beach to Birth Records
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.
July 18, 2026
The Irving Legacy and Canada's Departure Tax History
July 18, 2026 This podcast was motivated by a comment on X by a U.S. immigration lawyer who commented that his Canadian clients rarely consider the applicability of Canada's "Departure Tax". Canada actually pioneered the concept of the modern Exit/Departure Tax. Although Canada did NOT have the first version of taxes imposed on emigration, Canada's 1996 tax found in S. 128.1 of the Income Tax Act was unquestionably the first of the modern broad departure tax covering a wide range of assets. Interestingly in 1996 the United States considered enacting what would in 2008 become the 877A tax but decided against it. Interestingly the reality of Canada's 1996 Departure Tax (which could result in double taxation) is addressed in paragraph 7 of Article XIII of the Canada/U.S. tax treaty and reads: "7. Where at any time an individual is treated for the purposes of taxation by a Contracting State as having alienated a property and is taxed in that State by reason thereof, the individual may elect to be treated for the purposes of taxation in the other Contracting State, in the year that includes that time and all subsequent years, as if the individual had, immediately before that time, sold and repurchased the property for an amount equal to its fair market value at that time." https://www.canada.ca/en/department-finance/programs/tax-policy/tax-treaties/country/united-states-america-convention-consolidated-1980-1983-1984-1995-1997-2007.html (This provision of the treaty appears to reflect OECD tax treaty commentary governing departure taxes.) In any event ... The history of Canada's Departure Tax is fascinating. The history demonstrates how a government response to the conduct of one wealthy person or corporation can lead to legislation destroying the lives and opportunities of the average or middle class person. For a description of how Canada's current departure tax works, see this post that I wrote a number of years ago: https://ustaxationabroad.ca/2013/07/31/canadas-departure-tax-vs-the-us-expatriation-tax/ Here is an AI generated podcast describing these issues. "The provided sources detail the historical and legislative origins of Canada's departure tax, specifically the deemed disposition rules under Section 128.1 of the Income Tax Act. The text identifies the Irving family of New Brunswick as the primary catalyst for these laws, noting how patriarch K.C. Irving moved to Bermuda in 1971 to shield his multibillion-dollar empire from the introduction of capital gains taxes. Journalists like Jacques Poitras have documented how the family utilized offshore trusts and captive insurance companies to move wealth out of the Canadian tax net. In response to these high-profile tax avoidance strategies, the federal government enacted a major legislative overhaul in 1996 to close loopholes related to international tax treaties. Today, the system functions as a "last shot" for Canada to tax accrued gains on global assets before a resident departs. These measures ensure that wealth generated within the country is subject to domestic taxation regardless of the owner's future residency."
191 total episodes available
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- What is PREP Podcaster - ”Success Favours The PREPared Mind”?
- How often does this podcast release new episodes?
This podcast updates weekly.
- Where can I listen to this podcast?
This podcast is available on 10 platforms including Apple Podcasts, Spotify, and more. You can also use the RSS feed directly.
- Does this podcast accept guests?
No, this podcast does not typically feature guests.
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