Liberty and justice for all United States persons abroad

The Isaac Brock Society

The Isaac Brock Society Was Ahead Of It’s Time In Fighting For An Independent Canada

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History doesn’t repeat itself exactly. But it often rhymes!

Then and now – Issac Brock and @isaacbrocksociety.bsky.social have been supporters of a free and independent Canada.More about Sir Isaac Brock below …www.cbc.ca/news/politic…

— Isaac Brock Society (@isaacbrocksociety.bsky.social) 2026-04-24T18:49:03.474Z

In the  article linked above and featured in the Bluesky post above, CBC reporter John Paul Tasker writes:

 

Prime Minister Mark Carney stunned some Canadian historians over the weekend when he released a pointed video message about the U.S. featuring a War of 1812 general who led the charge against the American invaders of that era.

For the first time Sunday, Carney publicly disclosed that he takes daily inspiration from Sir Isaac Brock, a foundational figure in Canadian history who expertly prepared Upper Canada for a possible U.S. invasion and then defended the territory against the marauding American forces when they eventually marched north.

A spokesperson for Carney said comedian Mike Myers gifted him a figurine of the general during the last election — the day they filmed that now infamous “elbows up” campaign commercial — and Carney, a history buff, has since given it a prominent place on his desk at 80 Wellington St.

This is an excerpt from a really great article that is absolutely worth the read in its entirety.

Towards the end he writes:

Arthur Milnes, a political historian and an ex-speechwriter to former prime minister Stephen Harper, said so many Canadians know little of the country’s history.

While a giant in that context, Brock remains an obscure figure for many Canadians, and that’s an indictment of the school system and the curriculum that’s taught, Milnes said in an interview.

Milnes said Carney’s invocation of Brock, the Plains of Abraham and the country’s royal ties is an effort to inject the past into the present and revive a part of Canadian identity that had gone dormant before this trade war.

https://web.archive.org/web/20260424014557/https://www.cbc.ca/news/politics/sir-isaac-brock-mark-carney-9.7170975

 

In 2011 the Isaac Brock Society was founded as a blog to educate Canadians about the impact U.S tax overreach. Specifically,  United States reaching into Canada and claiming Canadian residents as U.S. tax residents. Not only was (and is) FATCA an attack on individual Canadians,  it was also an attack on Canada’s status as a sovereign country. The “realization of the attack” was often referred to by impacted individuals – as the “Oh My God” moment.

 

In 2025 Canada as a country had it’s “Oh My God” moment when it realized that when President Trump suggested that Canada should become the 51st state. The President’s threats to annex Greenland gave the threats against Canada more credibility. In 2025 and 2026 the world had its collective where it recognized the need to deleverage from and minimize dependence on the United States.

 

It was in this political and historical context that Mark Carney became the Prime Minister of Canada and has become a champion in the cause of keeping Canada independent from the United States. Note that this is NOT “Anti Americanism”. Rather, it’s a simple recognition that Canada (like other countries) must take steps to create economic independence and to diversity its interests as much as possible.

One of the founders of the Isaac Brock Society sent me the following video clip giving more information about Sir Isaac Brock.

 

— Isaac Brock Society (@isaacbrocksociety.bsky.social) 2026-04-20T22:21:27.987Z

It’s 2026. Canada must deleverage from the United States to preserve its independence and protect is sovereignty.

History doesn’t repeat itself exactly. But, it does often rhyme!

 

John Richardson

 

Heather Richardson and Vanessa Williamson – The Price of Democracy: The Revolutionary Power of Taxation in American History

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Interesting discussion about the role of tax."The Price of Democracy: The Revolutionary Power of Taxation in American History" between @heatherrichardson.bsky.social and @vanessawilliamson.bsky.socialTaxation is American and America is taxation!heathercoxrichardson.substack.com/p/american-c…

— John Richardson (@expatriationlaw.bsky.social) 2026-04-20T01:43:12.212Z

F. Scott Fitzgerald of “The Great Gatsby” fame once wrote:

 

“Let me tell you about the very rich. They are different from you and me.”

For many years various “Americans Abroad” groups have been trying to have a rational conversation with American politicians and the general public about ending citizenship taxation. The discussions are very difficult. The difficulty is largely rooted in how Americans view taxation. I guess I could say:

“Let me tell you about how Americans view taxation. They are different from you and me.”

It has become painfully clear that America is about taxation and taxation is about America.

And speaking of the role that taxation plays and has played in American history and democracy, it’s worth listening to this fascinating conversation between Heather Cox Richardson (no relation) author of the substack “Letters From An American” and Vanessa Williamson of the Brookings Institution.

Their discussion is about Ms. Williamson’s new book: “The Price of Democracy: The Revolutionary Power of Taxation in American History“.

Incidentally, Professor Heather Richardson is leading the opposition to the Trump administration. Whether you are to the left, to the right or an independent, I recommend her Substack. She does an amazing job of putting current events in historical perspective.

John Richardson

 

 

Second Estate – How The Tax Code Made An American Aristocracy – Ray Madoff

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As goes tax policies of a nation, so goes the survival of the civilization.BC Law Prof Ray Madoff explains how and why the US tax system has created tremendous inequality and "aristocracy". Bottom line: "Salaries are for suckers"This video is worth watching!www.nytimes.com/2026/04/17/o…

— John Richardson (@expatriationlaw.bsky.social) 2026-04-19T11:57:05.254Z

Thanks to long time Brock contributor Tim Smyth who introduced me to this fantastic article/podcast.

Ray Madoff is a Boston College law professor who is the author of a number of books including:

Second Estate – How The Tax Code Made An American Aristocracy

____________________________________________________

Why this interview is important …

Americans abroad are acutely aware of the unfairness, arbitrariness and weaponization of the U.S. tax system. There are multiple layers of unfairness. The institutional layers of unfairness include (but are not limited to):

First level 0f unfairness – defining tax residency in terms of the “circumstances of birth“ (citizenship) rather than the “circumstances of life” (where people actually live and where the activity in their lives is centered).

The unfairness includes taxation of people based on “status” (citizenship, immigration status) without regard to whether people live in the United States. The “status” based unfairness is discussed and understood only by those impacted by it.

Second level of unfairness – taxing different forms of income and assets differently

This is where this interview with Ray Madoff really shines! At the risk of oversimplification, Professor Madoff explains:

– how the tax system discriminates against people who receive their income in salary as opposed to investments; and

– how this discrimination facilitates the tremendous inequality of wealth in the United States; and

– how the tax system perpetuates and entrenches this inequality of wealth from generation to generation (hence the word “aristocracy“).

Question:

Why should income from capital gains be taxed at a lower rate than income from work?

The U.S. tax system appears to operate in a way that exempts the super wealthy from the same levels of taxation that are experienced by wage/salary earners.

I highly recommend this interview. It is the most educational hour that I have experienced in a very long time. Understanding this interview will equip you with a better vocabulary and understanding to discuss tax policy.

At one point Professor Madoff draws a direct comparison between the Canadian and U.S. tax systems. There is a brief exchange about citizenship taxation and renunciation of U.S. citizenship.

An incredibly rich discussion …

Listen to this podcast! I promise you will benefit.

John Richardson

 

The interview on YouTube:

 

 

Links to the original New York Times article:

https://www.nytimes.com/2026/04/17/opinion/ezra-klein-podcast-ray-madoff.html

https://www.nytimes.com/2026/04/17/opinion/ezra-klein-podcast-ray-madoff.html?unlocked_article_code=1.cFA.Ik6N.JNRWj6ASShrt&smid=url-share

You Know A Tax System Is Broken When Individuals Fear Tax Compliance As Much As They Fear Tax Noncompliance

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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

Part A – Why tax systems be restricted to taxation and not be used as a mechanism to enforce immigration laws

The New York Times article includes:

For decades, the I.R.S. implicitly encouraged undocumented taxpayers to file a return as part of its broader mission to promote tax compliance. Before the agreement between the I.R.S. and ICE, unauthorized immigrants paid roughly $60 billion annually in federal taxes, according to an estimate by the Institute on Taxation and Economic Policy, a progressive think tank. Much of it went to Social Security and Medicare, which are programs that undocumented immigrants cannot benefit from.

With few exceptions, taxpayer information was kept walled off from other government agencies, and that won a measure of trust among many undocumented immigrants. But under President Trump, the effort to find as many immigrants to deport as possible led the administration to try to exploit that trust.

Bottom line: The assumption that the information in a tax return would not be shared to other government agencies has been shattered. The “undocumented” have reasonable grounds for worry.

Of further interest is:

John Koskinen, who was the I.R.S. commissioner from 2013 to 2017, said the potential consequences of sharing tax data with D.H.S. were evident.

“Our job was to collect taxes owed, not enforce immigration laws,” said Mr. Koskinen. “That was the job of D.H.S. And it was clear to me that, if immigrants thought their information was going to be shared, many of them would quit filing their tax returns.”

The link in the article is a “Gift Link”. Hence, you can see the comments which are interesting.

Part B – Thinking about the FATCA related transmission of taxpayer data to the United States

Continue reading →

Naturalized U.S. Citizens – David Frum Of Canada and Fareed Zakaria Of India – Discuss Their Feelings About U.S. Citizenship

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Fascinating discussion between two well known naturalized U.S. citizens – @davidfrum.bsky.social and Fareed Zakaria – about the the meaning of U.S. citizenship and where the U.S. is today. Consensus: USA has changed and not for the better.youtu.be/hHEoPFrZIhw?…

— John Richardson (@expatriationlaw.bsky.social) 2026-04-08T21:46:20.478Z

This post is NOT for everybody. But, it is a fascinating discussion between two well known naturalized U.S. citizens about America today. It lasts about a hour. I would say it is a discussion with a 40 year perspective and a good deal of substance.

 

John Richardson

 

April 1, 2026 – The Supreme Court Will Hear The Trump Administration Argument’s For Restricting Birthright Citizenship

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Prologue

Interesting article and even more interesting comments on the 14th Amendment "birthright citizenship" issue.The Trump v. Barbara case to be heard April 1, 2026 will probe which individuals born in the USA are not U.S. citizens at birth.www.nytimes.com/2026/03/30/u…

— John Richardson (@expatriationlaw.bsky.social) 2026-03-31T09:07:48.861Z

 

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. An excellent analysis of what to expect is here.

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.

This case will be of particular interest to the “Accidental Americans” community who do not believe that they should be treated as though they are U.S. citizens. President Trump may agree with them. Specifically, you can expect the Trump lawyers to argue  – as per his January 20, 2025 Executive Order that:

Among the categories of individuals born in the United States and not subject to the jurisdiction thereof, the privilege of United States citizenship does not automatically extend to persons born in the United States: (1) when that person’s mother was unlawfully present in the United States and the father was not a United States citizen or lawful permanent resident at the time of said person’s birth, or (2) when that person’s mother’s presence in the United States at the time of said person’s birth was lawful but temporary (such as, but not limited to, visiting the United States under the auspices of the Visa Waiver Program or visiting on a student, work, or tourist visa) and the father was not a United States citizen or lawful permanent resident at the time of said person’s birth.

https://www.whitehouse.gov/presidential-actions/2025/01/protecting-the-meaning-and-value-of-american-citizenship/

In Summary, it appears that the Trump administration will argue that “birthright citizenship” is not available to children born on U.S. soil to a mother who is neither a U.S. citizen nor permanent resident AND when the father is neither a U.S. citizen nor permanent resident.

My prediction (which is worth nothing)

The “Birth Tourism” industry will continue ONLY to the extent that the biological father of the child is a U.S. citizen or permanent resident. Yes, there are some circumstances where U.S. citizenship or Green Card status is a benefit! Male Americans abroad can become “registered sperm donors”. (Perhaps a side business to offset the costs of U.S. tax compliance abroad.)

If you are interested in a more detailed discussion (on the law and not the business opportunity for male U.S. citizens)  see my lengthier post …

 

Trump v. Barbara – Ending The “Birth Tourism” Presumption That Birth On U.S. Soil Is A Sufficient Condition For U.S. Citizenship

John Richardson

 

 

 

 

Some Americans Considering A Move To Canada May Already Be Canadian Citizens

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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 Canadian citizen father (making him a Canadian citizen). The benefits of “dual citizenship from birth” means that he will be able to avoid “covered expatriate” status (no 877A exit tax payable).

During the conversation it became apparent that he has a son who born in the United States and has always lived in the United States (about 25 years old).

Amazingly, due to a change in Canada’s citizenship laws that took effect on December 15, 2025:

1. The son (born before December 15, 2025)  IS a Canadian citizen!! All that is necessary is that the facts be proven to support that claim to citizenship.

2. Children born after December 15, 2025 to a “born abroad” Canadian citizen are Canadian citizens if the Canadian citizen parent has 1095 days  of Canadian presence prior to the birth of the child. (Do you think it might be a good idea to acquire that presence by attending university in Canada?)

Great news for a lot of people!

A “watered down” description of this is available here on the Government of Canada site.

I suspect that this change in Canada’s citizenship laws is a “gift” to many U.S. citizens. Think of it!

Many U.S. citizens (and of course citizens of many other countries) will have the right to be recognized as Canadian citizens. For those who don’t want Canadian citizenship, there is even a simplified procedure to renounce Canadian citizenship. Interestingly the cost to renounce Canadian citizenship is $100 CDN.

Further information is available here.

In a world where people are paying huge amounts of money for a second citizenship this is a bargain!

 

John Richardson

 

 

 

 

 

 

U.S. Citizenship Taxation Violates International Law

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Meeting Ellen Timmer

Ellen Timmer is a Dutch based lawyer who has been and continues to be very active in the opposition to FATCA and U.S. citizenship taxation. Included in the long list of her accomplishment is that she represented retired KLM Pilot (and “Accidental American) Ronald Aries.  Mr. Aries had to fight to retain a bank account in the Netherlands (which is his country of residence). See the podcasts below …

About FATCA and U.S. Citizenship Taxation

Of course, FATCA is simply a consequence of U.S. citizenship taxation. The practical meaning and reality of “citizenship taxation” is that it is simply the United States claiming people who live in other countries and taxed as residents of those countries should be treated as though they also live in the United States.

U.S. citizenship taxation is taxation based on the “circumstances of birth” and NOT on “the circumstances of life”.

This ridiculous notion is reinforced by both the “saving clause” in U.S. tax treaties and the FATCA IGAs.

An Attack On The Sovereignty Of Other Countries

I continue to believe that U.S. citizenship taxation is a violation of international law. I was very pleased to see that Ellen Timmer included my argument in 2025 post on her site.

The post is here:

US Citizenship Taxation Violates International Law | CBT, FATCA

 

Appendix – Meeting Retired KLM Pilot Ronald Aries

For those interested in meeting retired KLM Pilot Ronald Aries, here are two podcasts I did with him Helen Burggraf’s American Expat Finance News Journal.

Podcast 1

Podcast 2

 

John Richardson

 

 

 

 

 

Effective April 13, 2026 The Fee For A “Certificate Of Loss Of Nationality Will Be Reduced To $450

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Part A – The Good news!! – The Fee For A CLN Is Lower

I noted in my post of March 5, 2026 that the reduction in fees for a Certificate of Loss of Nationality was in the final regulatory stage.

The fee reduction for a CLN  from $2350 to $450 USD will  be in effect on April 13, 2026.

https://www.federalregister.gov/documents/2026/03/13/2026-04931/schedule-of-fees-for-consular-services-fee-for-administrative-processing-of-request-for-certificate

(As reviewed in the Appendix to this post, the delay in the fee reduction had been extensively discussed in my January 4, 2026 post.)

A “Certificate of Loss Of Nationality” will be less expensive and therefore more available

On March 13, 2026 the State Department published in the Federal Register a “Final Rule” which:

… adjusts the Schedule of Fees for Consular Services by reducing the fee for Administrative Processing of Request for Certificate of Loss of Nationality of the United States from $2,350 to $450.

This “Final Rule” is to take effect 30 days from the date of publication. This  means that the renunciation fee will be $450 effective April 13, 2026.

The fee reduction is NOT retroactive

The Notice is clear that the fee reduction is prospective and NOT retroactive.

To learn more …

Here is the pdf to the State Department announcement of the fee reduction for a CLN from $2350 to $450.

2026-04931

Commentary on X …

 

Continue reading →

Taxpayer Advocate To IRS: Your Task Is To Administer A Worldwide Tax System. Do it!

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On February 23, 2026 SEAT President Dr. Laura Snyder published an excellent article in Tax Notes.  The article discussed  the recent Taxpayer Advocate report which was sympathetic to the tax situation of Americans abroad. (I previously posted on the 2025 Taxpayer Advocate Report noting that: The IRS Has An Obligation To Meet Taxpayers Where They Are, But Is Not Doing So For Americans Abroad.)

Dr. Snyder expands the discussion …

The article examines the National Taxpayer Advocate’s 2025 Annual Report to Congress, which spotlights the difficulties faced by overseas taxpayers as one of the most serious problems of U.S. tax administration. The IRS’s failure to administer a worldwide tax system raises constitutional issues and has serious repercussions not only for overseas Americans but also for the tax system as a whole.

Her article is available here:

Taxpayer Advocate to IRS: Your Task Is to Administer a Worldwide Tax System. Do It.

 

John Richardson