Tag Archives: Andrew Grossan

Part 52 – December 5, 2023 – The Supreme Court Hearing In Moore v. United States

Moore v. United States – December 5, 2023


Audio of the actual hearing:

This podcast is an audio of the actual argument that took place before the court. The relevant link to the Supreme Court site is:


Significantly a transcript of the argument is available at:


The audio of the argument is also available at:



SEAT President Dr. Laura Snyder attended the hearing. A fascinating podcast discussing her observations (right after the hearing ended) is available here.


SEAT along with AARO authored an amicus brief which explained the how the 965 transition tax impacted Americans abroad.

IRS Medic hosted a podcast both before, during and after the Supreme Court hearing. A link to that podcast is here:

Interested in Moore (pun intended) about the ยง 965 transition tax?

Read “The Little Red Transition Tax Book“.

John Richardson – Follow me on Twitter @Expatriationlaw

Are you a US citizen? The US has two kinds of citizenship: Citizenship for tax purposes and citizenship for nationality purposes

The law of U.S. citizenship has evolved over time. It can sometimes be difficult to determine whether one is or is not a U.S. citizen. The difficulty has been exacerbated by the fact that in 2004, the United States created (what I will refer to as) the tax citizen.
It is possible to be a U.S. citizen for the purposes of taxation but NOT be a U.S. citizen for the purposes of immigration and nationality. This state of affairs could exist if one had (1) relinquished U.S. citizenship for nationality purposes, but (2) not taken the required notification steps to end U.S. tax citizenship. (It is also possible for one to have lost the Green Card for the purposes of immigration but still be subject to U.S. taxation.)
The difficulty is compounded by the fact that different rules have existed at different times.
For many people who do NOT live in the United States it would be prudent to undertake a careful evaluation of your U.S. citizenship status. This should be done before entering the U.S. tax system.
What follows are two videos of interviews with lawyers Andrew Grossman (2014) and Virginia La Torre Jeker (2018). By watching the interviews you will be introduced to some of the complexities of U.S. citizenship.

John Richardson – Follow me on Twitter @ExpatriationLaw