WEBVTT

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All right, some very recent news Donald Trump talking about potentially ending what he calls double taxation of US expats

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This could potentially mean an end to the US is very unique policy of

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You can check out, but you can't leave the tax system. We're gonna talk about that

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I'm gonna share with you an article from the Wall Street Journal came out a couple days ago

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And we took the time to do our own research and analysis on that

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We're gonna share comments from our own in-house

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What Michelle McCurry dubbed him at nomad countless live the tax terminator

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We got together and put our analysis together what this could mean for expats. It's just you me and my

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Barry Goldwater mug today. So let's start with the Wall Street Journal article

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October 9th Trump pledges to end double taxation of Americans abroad

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The idea is the latest from the GOP nominee that goes beyond extending the 2017 tax law now

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The 2017 tax law

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You could have read the Wall Street Journal in 2018 and I think 2019 there were articles about how that hurt

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certain expats living overseas

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so

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2017 tax law was not as great and Doug Casey and I talked about this at nomad capitalist live as you might think

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Dateline Washington Republican presidential nominee Donald Trump says he supports lowering taxes on US citizens who live abroad

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Marking a new attempt for the former president to win support from an often overlooked group of supporters now

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I get hit from both sides. He's become full maga

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I liked it when he was a real libertarian and on the other side

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I'm a crazy communist because I don't go all in with Trump on everything

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It does feel to me a month before less than a month before the election

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Really you just thought of this policy now. This is a citizenship pastakes citizenship based taxation has been going on

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Since the Civil War and by the what else what else came out of that was

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Birthright citizenship. You're born on US soil. You are an American. That's how I was an American when I gave up US citizenship

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It says it right in the form

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US citizenship was obtained by birth in the United States not that both of my parents are American

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and so, you know Trump was talking about that nine years ago and so hey

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You want to free Ross d'Albrecht? He said hey

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You want to do stuff? That's pro-Bitcoin that our team heard him talking about it Bitcoin 2024

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And now you want to end citizenship based taxation. Hey, this all sounds great

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You know where you've been happy to have converts not trying to be one of those guys who says, you know, you know

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Too little too late

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Does you know does a little bit feel like no taxes on tips?

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Now it's this. It's you know, hey, who can we get into the tent? Hey, listen, I'll take it

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The US has an unusual system

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That's right Wall Street Journal for taxing its citizens on their total income regardless of where they earned it and where they live making the United States alone

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among all major countries with such a rule and

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There was a rumor that Bernie Sanders had talked about ending this because it would fall under his we're the only country

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Country in the developed world that's still taxing citizens no matter where they live

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They're not using the roads and the bridges and so the US does have this now

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If you have active income and particularly if you're an entrepreneur, you can use the foreigner an income exclusion

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If you're living in another high-tax country, you can potentially use a tax treaty

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There's different things you can do to reduce your

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Income for folks like myself who did not want to move from one frying pan to another who wanted to go to a lower-tax jurisdiction

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Being an entrepreneur using the foreigner an income exclusion did that

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I could have I think continued to pay zero tax

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But in recent years not everybody can pay zero tax if you make over that for an earned income exclusion even in the business

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So active income you're gonna pay something, but it's a lot less if you move overseas

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Passive income is a different story

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Passive income, you know, they don't really exempt that so much so people who are in Bitcoin for example

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You know, that's why many of them give up their citizenship. It is pure unlike in my case

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It was you know, their case is pretty much. Hey, I just don't want to pay all this tax

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Other countries use systems that base taxation on where people live. So we talk about becoming

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What we call a tax non-resident

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Canadians Australians Germans they are making it more difficult. They're putting more tests

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They're being a bit more strict on what the rules are and how they're enforced

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But you can leave their tax systems while keeping your citizenship

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And then you if you want to move back to the country in the future as a citizen you can

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I think they will make it more difficult

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I don't know that they'll go full-scale us but they'll do something like that eventually some of them

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So essentially the article says an American living in Paris would have tax obligations to both france and the u.s

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Now they're not going to be paying you know 90 percent

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But they're going to have the tax obligations

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Though the u.s tax could already contains features meant to mitigate double taxation or french citizenry not residing in new york typically wouldn't pay

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Wouldn't oh france any taxes on u.s income

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Yes, that's correct

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And there are times when if you are an american and you pay a certain amount somewhere

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You need to top it up to the irs to the u.s. Which seems unfair, you know, you didn't you know again

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We help people move to pay zero percent tax five percent tax. We have some people now. Hey, I'll pay 10 or 15

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That's fine. I'm happy to pay something some still want to pay zero

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Those the places where it's harder to go but to tell kind of the average american expat

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You don't pay anything or sorry. You're paying

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25 30 percent

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Hey, you got to top it up a little bit to to be even with us

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That's one thing and that's bad enough, but you've got to file a return

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You've got to file reports for your foreign bank accounts if you've got a foreign corporation

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You've got to file all that paperwork with the u.s. Government. So it's not just the obligation to pay

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It's the obligation to file. It's the obligation to go through all the paperwork. We had one guy once

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Uh client many years ago

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With the structure he had it's like hey if he's going to make this move

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As an americans, you know overseas

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I think somebody quoted as $50,000 a year to do his taxes

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It was going to be that complicated for the kind of business he had

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And he wasn't you know, the guy wasn't making a hundred million dollars a year. I think he was making

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Three or four million dollars a year. So that's insane for a country. He literally didn't want to live in a single day

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So trump says according to a statement he sent to the wall street journal

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Quote unquote. I support ending the double taxation of americans

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Overseas or overseas americans

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I'm going to come back to how we may interpret that in a minute like his prior campaign

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Ideas to eliminate taxes on tips social security benefits and overtime pay

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Trump's latest tax policy promise goes beyond extension of his expiring 2017 tax cuts

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And the ideas he pushed during his first term as president and it's aimed at targeting a demographic

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My opinion and I know that most people

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Uh, maybe won't see why I'm saying this but again talk to Doug go watch my interview with Doug Casey

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I think we touched on this a little bit and then go back and watch my interview with Doug Casey in 2021

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Both done at nomad capitals live

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Um, and and we kind of talked about the fact that you know the right wing

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It's a little bit jingoistic these days

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And do we entirely trust the right wing

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To not want to go after expats because hey if the u.s. Is the best country in the world

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Who would want to leave only a no good rotten trader, of course

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All right, uh, I've been on fox business before I don't remember if I've been on fox news

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But you know, we get a few comments people send in like oh, you know, you're trying people to leave

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You're you know, you don't want to stay and fight. It's like, well, I don't want to live there to begin with

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No, I don't want to fight the the

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The goliath I know I don't um, I don't be happy something that these people

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Um, some of these political animals I worked in talk radio and and I saw people in their 70s never been happy a day in their life

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Uh, yeah, I do not want to end up like that if that's what stay and fight looks like

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Um, but I I I do fear

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Uh, that at some point that's what a right wing administration somewhere does now there are this is where culture comes into play

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Is if a country's culture is emigration in its history, I think there's a great there's a lot more understanding

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And so you have countries like ireland which are smaller and they have to be more responsive to their citizens in some ways

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And people did emigrate and so there's an understanding. Hey, these people aren't bad people. They're just emigrating for their own reasons

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Or I think cultures against smaller countries where people, uh, you know, where they had

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You know, like a portugal where they were trading all over the world. There's a greater understanding

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Not everyone's going to live here. The u.s. Is a rather isolated country. I think

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Canada and australia, which are you know are in that basket, which is why I've said I could see them implementing some form of

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Citizenship based taxation first because there's not an awareness of all these other places

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Perhaps the way you have in europe where you're a lot closer together

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So I I don't that that's my opinion. I'm not saying I I you know, I'm a capitalist

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I generally voted for right wing candidates unless I was protesting

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How bad those right wing candidates are when I was in the u.s. But eventually I realized the right wing is not going to

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Save you either and as I was talking to some folks in my family the other day

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They're like the country's too far gone for anyone to save it no matter how hard they try

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So that's my uh belief on this

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The article goes on and on uh one thing says a more expansive revision the tax code could open opportunities for wealthy

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Americans to move overseas retain their citizenship and escape some u.s. Taxes. Yes the same way that people in every other country

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uh get to do

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Again, I I think that a couple other countries are creeping into

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Making it harder to leave but the u.s. Is alone and you know, what's one way to test whether your country or your

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Any relationship you have if it's one versus a hundred and ninety five

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Or I guess in this case two Eritrea versus a hundred and ninety four

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You know

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Maybe you ought to listen to the other 99 percent

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And when you don't that says something about your culture. It's a culture of arrogance

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Um

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And so here's the main point. I'm gonna get into that

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What trump means by double taxation remains uncertain and the campaign officials offered no additional details

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About exactly what policy change you would try to push through congress

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I don't really care who wins. I don't have a dog in this fight

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um, again, I I've

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part of my

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Leaving the u.s. And eventually giving up citizenship. I am politically homeless and Americans have a really hard time

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Understanding that these days. I mean to go back to my days and talk radio

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You couldn't even back then and you certainly couldn't today have anything where you know, if you had a radio station

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It's not just trump trump trump trump trump or anti trump all day long the anti trump stuff never works on talk radio

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But uh, you know, if you if you're if you're not in lockstep anymore people are like you're a communist

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And I just look at this and I say this just feels a little bit like pandering. Oh, the democrats do it too

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Okay. Well, great that everybody sucks

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But here's the analysis from our own in-house

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What michelle McCurry called the tax terminator?

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um

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Donald trump has come out and stated he wants to end double taxation for americans

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What does our preliminary research indicate the statement can be a broad spectrum of things and as of now

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We don't have any specifics available as the wall street wall street journal says

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Trump's comments could lead to any of these

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Uh scenarios a through f

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Option a the end of citizenship based taxation all together

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So this is the policy where no matter where you live

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You at least have to file a tax return report all your bank accounts report your corporations report your trust

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It's laborious

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Maybe you don't owe anything due to any number of reasons we help people again

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We help americans lower their taxes a lot all the time

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But there's still the obligation to be on the hook even if you're getting lots of exemptions exclusions. What have you?

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So option a is they just give her the whole thing

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Given the wording of the comment trump made double taxation for americans living abroad emphasis on double taxation

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We believe this option is the least likely

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And do not believe the u.s. Will leave expats in tax havens like dubai or the cayman islands alone so easily why well

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I haven't lived in the u.s. For a long time, but you know back then you'd watch the political attack ads

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You know so and so is in favor of you know

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Giving more money to companies that ship jobs overseas

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And when you get into the offshore tax game, you kind of realized okay

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I kind of understand what they're saying, but they're overly simplifying it to make the average person not like that person

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Not not like that candidate

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And so I think it would be pretty pretty politically expedient to you pretty politically expedient

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Of either party to say you know what yeah those those those people in france

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We're going to leave them alone, but if you move to somewhere like dubai all bets are off or the cayman islands

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We're not letting we're not letting as the article the wall street journal says wealthy americans could be able to live overseas and not have to pay tax anymore

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Right again like everybody else does and in in in going along with you have to pay taxes for the roads and the bridges

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Even though they have roads and bridges in the cayman islands, and it's still zero percent

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But yeah, you got to pay for the schools. Well, you're not using any of those things anymore. So why would you pay?

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So option a we think is the least likely from our own research from the tax terminator

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Option b a sharp increase of the foreign earned income exclusion. This is how much you can earn in active income earned income, right?

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Are you doing the work?

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Basically they could raise that up and therefore, you know if you're a business owner or

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If a salary more money tax-free and this would be a good thing if they did it because

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If you live what a lot of our clients do in contrast with the average expat does you might be living a tax-free life

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And so therefore the more money that you're also not paying to the u.s

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That's zero on one side zero on the other side. That would be good now. How high are they going to raise it?

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Uh, you know probably not into the millions

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Um, but perhaps the system stays the same

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But the fve has increased substantially to provide much greater relief to upper middle class american professionals lawyers doctors

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accounts, etc some of them by the way don't qualify for the foreign earned income exclusion because

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um

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Their businesses are not truly businesses. They don't they don't fully qualify for the fve and high level workers

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Living abroad. Yeah, I had a friend who um

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Lived in Abu Dhabi made a million dollars a year was a u.s citizen

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He did not run that through a company because he was an employee. He couldn't they just pay him. Here's your money

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Um, and he was paying tax on 90 percent of that money as if he lived in the u.s

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Despite living in Abu Dhabi big disadvantage

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Uh, so option b is they exclude more money if you're a seven or eight figure entrepreneur. I doubt that's ever going to keep pace

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Um, but it could be more relief

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and quite frankly the restrictions on what you make above the fve and it's it's um

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You know, there are some restrictions there for sure

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Option c we might potentially see an exemption from cfc rules controlled foreign corporation rules for americans living abroad providing

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They meet certain conditions for example a u.s citizen entrepreneur becomes a bona fide resident of a nice country

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And this is what i've told you i've suggested this a few times over the years

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Uh, i.e a country with it which the ua e uh us. Hey the usa is a tax treaty

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So i've suggested. Hey some countries might kind of do like a back door of what the us is doing

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But they'll carve out countries they like so let's say, you know in france

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We talked about recently one of the candidates for was a president or prime minister

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Wanted to implement citizenship based taxation did not get in so fine. We will live to see another day

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But my thought was always that maybe a country in europe

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Would say okay if you moved with if you moved to other e u countries. We can't or won't bother you

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So therefore you could move to ireland or malta or cyprus and be a nondom if they included the um the broader

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You know ea countries you can move to switzerland do a lump sum you can move to poland for the lump sum

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Um, you can move to idly for the lump sum grace for the lump sum

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uh spain for you know their program

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Um and so theoretically

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You know somebody who has a european passport is afraid of this happening

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But their place to move would be within the european union

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Maybe that'd be more likely to stay an option and so now

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Uh our team is suggesting. Hey the us might exempt you

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Uh entrepreneurs and business owners from rules

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That include your companies in the equation if you move to a country with which they like and so that may be exempted

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from guilty

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Um, which is a whole new formula under the tax law on um, you know, low and intense, you know

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Low tax and intangibles and all that kind of stuff as well as sub part f which became broader

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Uh under the last tax law provided their businesses also incorporated there

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So it could be something where uh again, let's take those nondom countries ireland cyprus cyprus and malta

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Have relatively favorable corporate tax regimes

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Now depending on how it works

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You might be you might still have some of the same restrictions on how you use the money

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um because of their mitten spaces

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but

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um

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That could be one way that the us could say all right fine

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If you go to another country and you incorporate there like, you know

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Don't be shopping around would be option c you can't put your company

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In the cayman islands and then go and live in a nondom country and then never remit the money

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And you're essentially living on you know very very very low taxes

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But if you incorporate into place where there's, you know

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Five or ten or twelve and a half percent tax on your business and they're on our nice list

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All right, we'll leave you alone

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Now the challenge would come and play with some of the lump sum countries

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Maybe switzerland could work although it's a lot of work for certain people

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um

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Italy wouldn't work because italian corporations are a mess

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But the lump sum is a good deal

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So if you had to incorporate in the same place that wouldn't be ideal

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So you'd still be paying something

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But you'd have more places to live in

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And if you are the person whose wife will only move to spain, I guess that would well it wouldn't work for you because spain

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I don't know if they include the canary islands or something

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Anyway, the option c is you get an exemption on some of the taxes on your business to where you just run the business

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If it's incorporated there and the us could leave that alone

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Option d we could potentially see capital gains tax exemptions on investments made in the country of bona fide residents of

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US citizens abroad for instance a full capital gains tax exemption

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Drive from the sale of properties or certain types of businesses provided certain criteria are met

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By the way, do you know who did renounce his us citizenship?

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purportedly for tax purposes

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former uk prime minister boris johnson who sold

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Uh a property in london, but he was born in new york and he therefore had a us passport

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The uk exempted his sales his primary residence and the us said well, uh, no one else is taxing that you're our citizens

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So please, uh, please send us the money and he said how ridiculous that was

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I think eventually it was surmised. He paid and then he renounced his citizenship. That's my understanding of the situation

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Uh, and so could the us say if you live in a country as a bona fide resident? That's a that's a term that's

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You know part of some of these equations. Uh, we're not going to tax you on that

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But would they say hey, you're a bona fide resident in

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uh tax friendly malta

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but

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Um, we're not going to exempt those dividend free stocks

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in singapore

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Uh, that's option d would be where you live. You might get some exemptions with that exempt capital gains on bitcoin

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Would seem perhaps not now. Maybe if you hold it in an exchange in that country, I don't know how that would work

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Uh, but option d could be some capital gains tax exemptions. That doesn't sound too good

19:52.040 --> 19:56.100
Option e might be us citizens who moved in nice countries again

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i.e with a tax treaty so countries that aren't taxing zero

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fully exempt from us taxation or at least to a large extent and then option f was a combination of

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Uh, the previous four options

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So it could be you get more foreign and or nicom exclusion and they exempt capital gains where you live on certain assets

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Maybe you sell a business in the country of residence

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And you pay some tax there and the us doesn't make you top it up or you sell your house

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And there's no capital gains tax after x years and so the us leaves you alone

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uh

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Some version of that

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in conclusion

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Our team and this is our opinion just from what we've read and kind of dug a little deeper. Um

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You know, we have

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You know a couple people in house who are you know trained in this area

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And of course we have a network of experts we work with

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But in conclusion, it is unlikely in our view they say that even under donald trump

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The us will completely abandon citizenship based taxation. However, we could see increased exemptions

20:56.340 --> 21:01.120
And opportunities to utilize tax treaties proper tax planning may be needed

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Probably will not mean things are as simple as just moving to another country. And again, even if you're leaving canada

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It's not just as simple as just move to another country. There's still planning involved

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Even when there isn't citizenship based taxation

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Uh one thing to point out here is the us may potentially reconfigure the exit tax

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So that is triggering people to part the us as opposed to when they

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Uh renounce us citizenship i.e. again, how canada does it? So be careful what you wish for to some extent because if you are able to get out

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It's going to be interesting to see how good are they going to make any of these restrict any of these

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You know improvements to double taxation

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To where maybe they say, okay, listen, you can leave and we're going to give you more exemptions

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And we're going to give you certain exclusions if you move to the right place

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Uh, but hey, when you leave you have to pay the exit tax then because we're going to have a new category of taxed on residents

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So the idea that you should just sit around in the us waiting forever

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Um is wrong and what I would suggest is

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That might move americans

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Into more of a plan a camp than a plan b camp

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We've had a lot of americans who say get me the second passport get me the third passport

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Get me a house that I can move to i'm going to start getting comfortable with that

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And if things ever get squirrely enough

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I might just have to push the exit button on the whole place

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Whereas if you're saying hey, I can move overseas

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Um, and I can get you know, I can reduce my taxes more easily as an american under this law

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Uh, the goal would be to move as soon as possible now

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The goal is always to move as soon as possible if you're trying to reduce tax because the longer you stay in

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The bigger the exit tax will be but if it's not based on expatriation and giving up your citizenship

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Based on simply moving abroad under one of these options or something else

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Um that potentially brings the obligation to pay an exit tax forward

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In which case you'd want to get out sooner than later to minimize that exit tax obligation

22:50.360 --> 22:54.860
So there's a couple good things quote-unquote about us citizenship based taxation

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One is you don't really need a tax resident somewhere else everyone views you as an american taxpayer

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Uh, and the other one is

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You know, you have a little bit more flexibility because of that about how you you know

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What you've what you've got to do to exit the us tax system

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And so some of those benefits may go away if the us allowed you to get out

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Our view we'll see what happens. We'll see if Trump gets elected

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Our view is that citizenship based taxation will in some form continue

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And for me, I mean, that's just again part of the culture. We own you

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And I I I pushed back more on the culture than the taxes because I I said this repeatedly

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I paid zero most years. I think I paid eight or nine thousand dollars one year and other years

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I was out. I paid zero. Um, I didn't have quite as unrestricted use of my money

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But didn't bother me at the time

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Because I was able to do things and I look back and say, you know

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I look back in retrospect and say it was a little bit messy compared to how I do it now

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But back then it's like whatever. It's messy. It's the price of being a u.s. citizen

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I wasn't paying

23:59.440 --> 23:59.840
um

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For me to think it's kind of offensive really offensive actually is

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Even if you leave our country, we're going to punish you because hey, why would you leave?

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Is it the best place on earth?

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So we're gonna, you know, so even if even if they even if they 10x the foreign earned income exclusion to over a million dollars

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Number one if you make more than a million dollars

24:19.420 --> 24:20.140
Okay, cool

24:21.100 --> 24:21.820
number two

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Is it about the numbers or it's about the principle

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I happen to think life's about principles. So that's our view on this

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We always like to take a couple days and actually do some research rather than just talking about it

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That's our view. I think Americans, you know, want to continue to have a second passport

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But I think that the equation is if you think there's any chance that this happening

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Where are you at financially now and where are you going to be at financially five years from now?

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It may be better to have some kind of plan a ready, which means you're going to be not living in the u.s. now

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Or in the near future

24:53.460 --> 24:54.820
To to take advantage of this

