good afternoon. This is John Richardson speaking with you from Toronto, Canada. Today is Friday, November the 1st, 2024, and November is, I would say, to put it mildly, a very significant month for Americans generally, and I would say Americans are brought in particular, and on that note, my guest today is somebody who I have interviewed in the past, but not for a long time. So I'm pleased to introduce to some and reintroduce to others Rebecca Lammers, who is the head of the DA Taxation Task Force, also a member of TAP, which I've never entirely cleared what that is, but it's part of the IRS in any case, but she'll tell us more about that, and she joins us today from London, where she lives and has lived for I think something like 15 years, am I right on that? 18. 18 year. Close enough, close enough. 15 divided, that's five, six. All right, I was 83 percent right. Okay. All right, so what's happening in London today? It's cold and dreary. Luckily, no rain today, but probably tomorrow. I didn't move here for the weather, that's for sure. Oh yeah, but it's not that bad. It's always in my theory that because the climate there is not prone to extremes, it's always been my theory that the climate was a major contributor to the growth and stability of the British Empire, but that's another... I would not disagree with that sentiment, yeah. Well, in every time, I'm sure you experience this too, because I know you've been flying around with all this tax and Americans are broad stuff, but you land back in Heathrow, which I guess is home for you now. Do you have a feeling that you're sort of landing in the center of the world, like when you look around at all the different people and they're coming and going in there? Yeah, I mean, it's definitely the center of the UK for sure. I don't know if you knew, but half the population of the UK lives in London, so this is where it's at. And the way I explain it to people in the states in particular, it's like you have the epicenter of politics is in DC, and then the entertainment industry is like New York and LA, and there's lots of different industries that are kind of spaced out in the UK. It's all in London. You got your politics, you got your entertainment industries, everything is here. So a lot of people who live in the rest of the country feel really left out. So there's always, they're always trying to distribute the industry, but it doesn't always work out. I guess a great reason to live somewhere other than London, actually. But okay. So let's go back to some beginnings here. I mean, you know, you're, you know, you're active on social media. I mean, the DA task force, the work is, you know, I would say front and center and we're really, really well known, but I don't have a sense that a lot of people know very much about Rebecca. So why don't we begin with the making of Rebecca? So you're from Ohio, I think, right? Yeah. So basically, yeah, I'm from Columbus, Ohio. That's where I grew up. I lived there till I was 18, and then I went to college in Wisconsin, small liberal arts college called Beloit College. And then I was lucky enough to do year abroad, my junior year. So I did a semester in Ecuador and a semester in London. And then when it came around to figuring out my next steps, I was applying to master's programs, and I got into both the ones in the UK and none of the ones in the US. So I just kind of figured, okay, well, I guess I'm going to go back there. And so I managed the decision kind of easier, actually, doesn't it? Yeah, it did. It did. Yeah, so Rebecca, what have you done if you've gotten into one US and one UK? What do you think you would have done? I think it's a good question. I think it, it would have depended on where it was in the US and also the cost. Like the, a lot of people come to London, especially from America to do education, because the education cost is so much lower here. And like, even though I didn't get a scholarship for my master's, it was still a third of the tuition compared to if I would have gotten into a program in the US. So there was a cost decision there for sure. Yeah, now that's surely significant, surely significant. Okay, now remind me, I know we've had these conversations over the years, and I always forget, but your master's program was in what? In music business management. So I went to the University of Westminster, and then I got a job. And then about a year later, I met my husband, obviously not right away, but at the time, the visa restrictions were a lot less than they are now. So I was able to get on a work visa. And then, and that was it, like, I was like, you know, a lot of, you know, Americans, if they're, you know, born in the US, when they move abroad, they move abroad for work family or school. And I basically ended up taking all those boxes. So like, my life just ended up being here. This is where I live now, you know, yeah. Well, just to say, I mean, do you, is it, would it be a true or probably true statement? That if the cost of your master's degree had been lower in the US, that you might not know anything about US tax issues for Americans abroad, would you say that's a likely? I wouldn't, yeah, I wouldn't hold that out, for sure. Yeah, so I mean, you know, part of the reason I asked the question is to make the point that this is an issue that only Americans abroad understand to be an issue, right? Yeah, I mean, I, so I started my business in 2014. And basically, I had continued to file, I used TurboTax for years. I actually, the only motivation I had for filing was because they would take my 1040 or my student loan payments. And they would calculate my payments based off of my income. And there's this whole thing where people are like, Oh, there's this conspiracy theory or whatever that if you file your for with the foreign or an income exclusion, then your AGI is zero. And then you don't have to make any student loan payments for US federal student loans. There isn't a conspiracy theory. It's a well known thing. So like, you can strategically decide to file with the foreign or income exclusion. And then your AGI is zero or negative. And then you don't have to make payments. And I don't know the background. I don't know what the policy decision behind that. But I did that for years. That was my motivation for filing was so that I I didn't have to make payments. I did anyway, just from a practical perspective, like it makes sense to pay down your student loans because my tuition, the percentage was like over 6%. So I was, I was like losing a lot of money just purely from the interest. But it allowed me to like manage my finances more and control. I had more control over my, my budget basically. Yeah, that's interesting. So, you know, the foreign or an income exclusion. So the word exclusion means that it just isn't included in your tax return as income, right? And so that has, you know, that has an interesting, interesting benefit. Of course, since we use that into the discussion, the flip side of that would be that you would not, without income, without earned income, you wouldn't be able to contribute to things like IRAs and, you know, that sort of stuff, if you were so inclined, either, I guess, right? Sure. But that's interesting, you know, strategic use of the foreign earned income exclusion. Okay. Yeah, so I did that for a long time. And then in 2014, I started my business. And then I just kept filing with TurboTax every year. And then a few years later, I was like, I think I'm doing this wrong. Like, it just wasn't like computing right. So I went to like six different accountants, and I called them up and they all, you know, spoke to me briefly. And I got six different answers on what they thought I should do. And I was just like, how is this, how is this happening? Like, I don't understand why there wasn't at least like a consistent, like, oh, you should do this, or oh, you should file it this way. No, they're like, some, most of them said that I should do the streamline filing procedure, which I was like, yeah, but I thought that was for people that didn't know that they were supposed to file. I knew I was supposed to file and I've been filing, I just filed incorrectly. And then they like, I didn't really get a straightforward answer other than the fact that like five out of six told me I should do streamline. And then like the wine, like that old, they had for crass seven out of eight, Dennis recommend crass. Do you remember that? Yeah, it's like that. Yeah. And then and then the wine told me, no, you just need to file amended returns. And essentially what I ended up doing was I was like, okay, logic dictates that you should go with the majority view. So I didn't go with the cheapest, but I didn't go with the most expensive. I went with the one in the middle to do the streamline filing procedure. And I also ended up owing tax for the year that I was actually laid off. And I didn't understand why it was like it didn't make any sense. So this all kind of happened around the same time that Trump got elected. And in 2017, I was just like, I need to figure out what is going on with this tax situation, because this is bonkers. So I started going to, and just to be clear, I'd never been a political person before 2017, or you know, it was really like a combination of like, what is going on with the world? And why is this like tax thing? How is this so confusing? Why isn't it clear? Like, I don't understand. And I actually started going to Democrats abroad events. And I was like, I remember the one in particular, I went to one here in London, and everybody went around the room and talked about like, introduced themselves and said like, what particular issues they cared about the most. And people were like, abortion or voting rights. And I was the only person that said taxes. And I was just like, I thought that's what you guys did. Like, I didn't really understand like, why were people talking about all this other stuff? I was like, I like, this is an American abroad issue. And then one of the people ended up connecting me with the taxation task force. And then I essentially like kept bugging them until they let me on the team. So that's kind of how I started volunteering for the taxation task force. And then like, many years later, so it was at the beginning of 2022 that I actually took over the team. And so it's been almost three years, which is really hard to believe, to be honest, because I think the direction that we've gone in under my leadership, like, first of all, the team before I took over was about a dozen people. So when I first started, I actually grew it. I was just like, we need more people. There's no way we're going to be able to do this with just a dozen people or, you know, more people need to be involved, more voices need to be heard in order to move this faster. So I grew the team from a dozen to 80 people within a few months. I want to pause for a minute and let listeners reflect on the gravity of that 12 to 80. That's remarkable. Yeah, and I still get people coming in. And they're all over the world. There are people that they're Democrats abroad members who, you know, American citizens living outside of the US who have been impacted one way or the other from from these tax laws, you know, and and everybody kind of has their own different view. Like, some people are really up up on the P fix or others on the retirement issues. And like, for me, I was I was like, my main driver was I wanted to pass residency based taxation. Like, I didn't understand why there was any other focus other than that. That was my main, my main personal motivation and remains my own personal motivation for for the work that we're doing. But I've learned a lot over the last three years. And and so I started that in January 2022. And then it was in March 2022 that I found out that I was offered the the taxpayer advocacy panel role. And at that point, I was just kind of like, I don't know if I can do both, but like, that's a lot. This is a big responsibility for a second. Okay, I mean, I think that people have a concept of what the Democrats abroad task force is. Right, but a lot of people have no concept of what the of what tap is. Yeah, so okay. Let me I'll take a step back. I think it would be good to explain what both of them are. So Democrats abroad is the like, the abroad arm of the, the DNC, the Democratic, Democratic National Committee. So that's the Democratic party within the United States. It's like the official party. And Democrats abroad is the official arm for all, all basically Democrats living outside of the United States. We're also the largest American abroad organization in the world. So like, we have hundreds of thousands of members. I don't know if it's in every country, but we have 57 what are called country committees. So there's like an official presence there. So we probably have like the widest few in terms of like the tax issues as it impacts Americans all over the world. And I'm very conscious that like some of our like partners, you know, the non-partisan like their seat and there's ACA and Arrow and like all non-partisan. And there, I think a lot of their members are potentially just based in in Europe. And so some people get more of a European perspective on what's going on with the tax issues. But we really truly have a global perspective because we have members and also like people that we can reach out to in each the countries. Like I often do that where I like contact people in Mexico and I'm like, Hey Mexico, is this a problem for you guys? Like do you have this issue? So it really helps to have that perspective. So the Taxation Task Force is the dedicated volunteer group within Democrats abroad, specifically focused on the the tax reform for Americans abroad. Like that so that's that's what our our volunteer group is. And we're all volunteers, nobody's getting paid. So all of all of my trips, everybody that comes along from Democrats abroad to the congressional office meetings that we do in DC, we're all doing that on our own dime basically. Yeah, great job is largely to pay for your night advocacy work. Yeah, almost, almost. Yeah. So so that's DA. And then the Taxpayer Advocacy Panel, it's not actually part of the IRS. It's independent of the IRS. But I think it so basically it's what's called a federal advisory committee. And there are a number of those if you just Google that search term, you'll find that across the board for various different agencies in the US government. But this one in particular is dedicated to having the taxpayers perspective be shared with the IRS specifically in order to put forward ideas and recommendations that will improve customer service and communications with the IRS to the taxpayer. So basically your role is to the extent that you can at least get the view from Americans abroad into the discussion. Is that is that a fair statement? Yes, but it's also about putting forward new ideas and also sparking new discussions. So like the way that it's structured is there are, I think it's six committees within the Taxpayer Advocacy Panel. Again, all volunteer based, so I'm not paying under under TAP. TAP is the acronym for the Taxpayer Advocacy Panel. And essentially, there's at least one volunteer member from every state and one international member. So I am that one international member. And everybody is on what's called a committee. So there's a committee for like the toll-free phone lines. There's a committee that specifically works on putting forward recommendations to improve IRS forms and publications. There's one specifically for the taxpayer assistance centers, which don't exist abroad. So I mean, there's literally no point in me being on that particular committee. But I'm on the reinforce that there isn't one. Right, yeah. And so I'm on what's called the Spectral Projects Committee. So traditionally, it's kind of been known as like the committee that works on stuff that doesn't really fit into one of the other committees. But a lot of it has to do with like either identity theft or ID verification or international issues is what they call a lot of the American abroad kind of tax stuff falls under the kind of international term. So yeah, it doesn't really make sense for me to be anywhere else or for whoever whoever is the international member. I don't believe that the international member before or going forward will ever be on another committee. But essentially, how it works is we meet once a month. We also have subcommittees that meet once a month. And we work issues. So essentially, anybody can go to the Taxpayer Advocacy Panel website and submit an idea for improving the IRS or like we got a lot of people who submit complaints and like ideas and things that they think the IRS should do better. And we essentially take those on board and then the ones where we can identify a systemic issue so where it impacts multiple taxpayers. We work that up as a recommendation and submit it to the IRS. And the IRS is required to respond to our recommendations. So like, yeah, this would be the way you're describing this. I think it's important to make this point that this is a committee or whatever tab is an organization that exists to advise the IRS within the context of the existing laws. Yeah. Yeah. So it's going to be clear that is not about advocating for residency based taxation at least directly. No. And one of the things that I've really benefited from through my work through the Taxpayer Advocacy Panel has been really understanding the difference between legislative, regulatory, and administrative, like really being able to know where you can ask for what basically because even the IRS as a federal government agency, even though they're aware of whatever kind of laws, it's not up to them to change the law. It's up to their job is to implement the law as Congress intended. And like, they are put in a difficult spot sometimes because sometimes the laws aren't drafted very well, right? So they basically try to do their best. But ultimately, like, that's where sometimes there are conversations between the IRS and like Congress to come up with solutions on some of the more difficult things. And in particular, on the international or the laws impacting Americans abroad, I think that's something I've been really encouraging wearing my Democrats abroad hat is trying to incite more conversation. So like an awareness of the difficulty of these laws and the impact it has on Americans broads lives, right? So there's completely non-partisan though, right? So the Taxpayer Advocacy Panel is non-partisan. Yeah. So that's there's 100% just like some of the recommendation like, did I lose you? Sorry. Yeah, even a little choppy there. It's okay. Let's just keep going. Sorry. Okay. You know, or at least I was asking you to confirm my belief that it's the tap as a nonpartisan. So when you're there, you're not wearing your Democrats abroad hat, you're wearing your taxpayer hat, so to speak. Correct. Yeah. So some of the kind of administrative things that I've worked on over the years have been like, well, those were open up until 2015 when the funding was cut. So I still get emails from people who are like, oh, I didn't even know that the tax attache isn't open anymore, like even though it's been nine years. So people living abroad aren't even aware that that service doesn't exist anymore. But like other kind of things like having like a callback option when somebody calls the IRS so that they don't have to wait on hold and burn international like expensive international minutes for like long wait times. And think things like that, things that are very like administrative focused, basically. All right. So this is your time, your service, your contribution. You probably see it differently on different days, depending on your level of fatigue, but it's coming to an end at the end of this month. You tell me, is that correct? Yeah. Yeah. I'm sad, but I feel like I've done what I could do in so everybody serves a three year term. So whoever the next taxpayer of international member will be, we'll probably find out sometime early next year. I don't even know. They select like there's an application process, an interview process and stuff like that. So I was your predecessor, the president of C, right, Laura Snyder was your predecessor. Okay. So I mean, you know, it's interesting to me that, you know, the last two international reps, you know, I'm both in very, very heavily involved in advocacy for America to broaden, you know, that surely cannot be a bad thing. All right. So, you know, here we are. I mean, this has been a really, really volatile period, politically, for the last year, probably two years, for sure. I mean, just generally, but I think also the issue of taxation of Americans abroad is I think more people are talking about it. I think more people are concerned about it. Yeah. It's obviously a good thing. So where do you see, I mean, you know, the history of this advocacy really dates back, I would say, to maybe 2010 or 2011, you know, when the problems began. And during those years, but you know, from my point of view, this is now, you know, 13, 14 years of, you know, trying to get sort of relief on these issues. And I'm kind of curious, you know, what's that saying in the Marines, the difficult we do today, the impossible takes a bit longer. I'm kind of curious how you see the evolution of this and where do you think Americans abroad are today and, you know, what's the objective? And that's the whole pile of questions at once. So why don't we start with how do you see the evolution of this? I remember meeting you briefly. You may not remember this, but I remember meeting you very briefly in 2017. I was at an event being hosted actually by, I think it was hosted by Republicans overseas. I'm not sure. Okay. But it was, it was some event to talk about taxation of Americans abroad. I remember meeting him. And I don't think you were quite involved in it, but you were visibly upset about it. That was my first image of you, Rebecca. Okay. I don't quite remember that, but that's okay. So, you know, so that's 2017. What's the difference, say between, so 2017 is your entry point into this and saying now, I mean, how do you see the evolution of the advocacy and, you know, just generally, including, you know, beyond DA? Well, I think before I kind of addressed that, I think one of the things that's really, even though my tap work has been separate from my Democrats abroad work, because one's partisan, one's non-partisan, so I keep a pretty strong firewall there. I mean, they clearly feed into each other because I was learning stuff through TAP that I then applied to the Taxation Task Force and also vice versa. So, like, for example, the National Taxpayer Advocates Report to Congress, which came out earlier this year, they always include some, there's always 10 most serious problems that they list in that report. And one of them was the taxpayers abroad. So, like, the year before, they kind of did a similar-ish, like, most serious problems. And I made it a point to keep in touch with the Taxpayer Advocate Service staff. And I think forming those relationships was really critical to getting some, like, really important points about the difficulties that Americans abroad face with maintaining tax compliance and also the unfairness with the penalties, the international information reporting penalties, and also where double taxation occurs, like, pointing these things out and getting them on the record. And I can see, like, I wasn't specifically quoted, but I could see in that report, there were multiple things that I told them that went into that report, a government nonpartisan report. That, in and of itself, was a really powerful advocacy tool that I was able to then use in my Democrats abroad work, walking into congressional offices and saying, "This nonpartisan, you know, National Taxpayer Advocate, the watchdog of the IRS, is on our side and making these points." And that was really powerful in order to really- I think that for one thing was really helpful for this year in particular, but it's one of those things where it takes time, like, even though I've been on the Taxpayer Advocacy Panel for three years, like, it's taken time for me to build those relationships with people. And I think the same thing can be said in my work with wearing my Democrats abroad hat with congressional offices, like, it takes time to build relationships with the tax writers in the different offices, right? So I think there's been a different strategic shift in terms of, like, setting expectations in terms of, like, what is achievable? What can we get done sooner rather than later? I know that I come under a lot of criticism from people who are like, "Why are you settling for incremental reforms?" I know that there was criticism about the direct file campaign that we ran. And I think it's really important to point out that, like, if there's one thing that the IRS should do, it should include Americans abroad in any kind of new initiatives, right? Like, it's such a low bar. How could they say no? You're not trying to pass that off as tax reform. You're just trying to say, well, you know, this is an improvement to the existing, you know, make life better in the here and now, right, is what you're really saying with that, I think, isn't it? Well, it's not... So I get this question from people all the time. They're like, they're saying, "Why are you settling?" I'm not settling. What I'm actually doing is, like, making it really, really obvious that they're saying no to something that they can say yes to for the IRS, right? Like, all they need to do is add one form to make it accessible for Americans abroad, and they can't even say yes to that. That's $2,500. You're referring to the foreign earning. Yeah. Yeah. And so, like, it's such a low bar. How could they say no, you know? So, like, that was the advocacy angle for that. And I also have to say that, like, RBT is not, like, less of a priority. I would say it's even more of a priority now more than ever, but it's through these, like, smaller campaigns, like with the Ford Trust reporting, the 3520 campaign that we did earlier this year, and the direct file, and then we're actually in the middle of a Pefic campaign, which we're really going to be pushing out after the election, like, by pointing out these specific forms or specific areas where it's literally impossible for somebody to comply because it's so complicated. And making that point directly to the IRS, we've done more calls with IRS and Treasury staff this year than we've ever done before. And they always are really appreciative. They always say thank you. We didn't know about this. We had no idea, like, this is the problem is that they're living in their silos, in their bubbles. They don't, they're not traveling abroad. Like, they don't know what's going on for us. And so, this is part of advocacy. Like, this is how it works. You know, like, it's a, the United States is a democracy, and it's a two-way conversation. You have to tell them what you want and advocate for it to get them to do it, because if you just sit back and you think that they're going to do it and read your mind, like, it doesn't work that way. Like, a lot of the IRS staff are normal, Joe Schmo, like, they, you know, they have a nice government job. They're not being paid very well, but they have great government benefits. Like, you know, think about it from, like, an individual perspective, like, how they, some, a lot of them have never traveled outside of the country, right? So, it's like getting them to understand our perspective and also advocating for the things that we want through the mechanisms that exist. That's really what we've been focused on. And like, and also, it's been a big learning curve over the last few years. Like, it's been a total shift in strategy, where a lot of it was very legislative focused. Like, we need to pass legislation. You know, we need an RBT bill. We need, you know, whatever. And I think by talking to the IRS and Treasury and adding that to the advocacy mix, it's really, I think, built our credibility on the hill, like, not only with the IRS and Treasury, but also with congressional offices, because it used to be where we would go into meetings with congressional offices. And they would say, oh, have you talked to the IRS about this? And we hadn't. So we didn't have an answer. So that's kind of where I started going, okay, well, they're asking us what the IRS is saying on it. So let's go ask the IRS and see what they say about it. So we did, and then we would go back to them. And then like this year, like pretty much everything that we talked about, we got questions like, oh, what does the IRS say about that? And we would, we were able to say right in the meeting, well, we had a meeting with the IRS, and they said this and this. And then we're able to have a much more productive and constructive conversation to the extent where we're able to get like, a next step action out of that meeting. So it is a lot of like, pounding on, pounding the pavement and knocking on drums. Well, let's talk about your campaign on the, you know, the 3520 thing. I mean, that was, that was interesting to me. I mean, I wrote up, you know, fairly lengthy submission on behalf of seed. Yeah, it was good. Thank you. That was, that was good. But what I found interesting was your ability. And you were at the, you testified at the hearing too. Yeah, what I found interesting was your ability to use your membership, you know, to get, was it like 1500? I think it was around 1500 comments and which, you know, seemed to me, to be for the prayer, was explaining why this was a problem for America to brought. Yeah. And, and that I think was an interesting, an interesting use of the, you know, the, the, the DA tax group, I don't know, you know, I mean, obviously not all those people are part of the group. But I thought that was interesting. And I mean, there's no way that that type of thing is not going to be helpful, right? I mean, I think it's, you know, how much, but what I appreciated about it was that when I was writing the thing, you know, I was a few times I said, you know, and as evidenced by 1500 complaints on this issue, you know, you know, just in case you think I'm making this up, you can't deny that that isn't an impressive number, especially if you, I can't remember how many people made a submission the last time or no, because that was for regulation. The, I can't remember how many people made a comment for the previous foreign trust regulation, but it wasn't, it wasn't 1500. That's for sure. You know, yeah, I mean, but of the, of the total, yeah, of the total number of comments. See, I actually, I love the opinion, I could not prove this obviously, but a number of the, what I thought were the sort of heavyweight comments coming in from fairly well-known lawyers and organizations, which came in at the end. I think we're likely influenced, you know, by the number of comments, you know, on the ground sort of thing. Yeah, I would agree. Sort of, you know, somehow the image of tag team, you know, comes to mind, right? Yeah, and actually, one of them reached out to us and actually thanked us for our comment, because it, it informed their, their comment as well. And, and we were cited in another one, I think, because we were, we were one of the first out of the gate, because it was a 60-day comment period during a really awkward time during the summer, when most people are pretty switched off. And we actually were really unclear on like, you know, that regulation is really not very clear. And, and even the new regulations were still not clear. And so we reached out to the people who drafted it and said, Hey, can we do a call before we submit our comment? Here's our draft comment. Can we do a call with you guys to clarify that what we are thinking is correct? And so we did a call with them. And what became clear is that what they're thinking and their interpretation was not being clarified in the draft regs. And so that helped us solidify our comment and recommend to them even further about where we needed further clarification. And like, look, this is really ultimately people should not be having to file 3520 or 3520A for a pension. That it just, absolutely not. It's just ridiculous. And, and really, I think that this was something that the IRS did. However, many years ago, in order to try to avoid any kind of like overseas tax evasion or, you know, loopholes and never intended for Americans abroad, it was. Yeah, they didn't think about us, right? They, this is one of the main problems. They don't think about us. And, and the impact that it has on the majority of people who are, are just trying to save for their future. So, like, I think, well, I am really trying to comply with us tax laws, right? I mean, yeah, which isn't possible, because not even tax professionals know what those regs say, you know. So like, if tax professionals are just recommending people file it, just to err on the side of caution and like, well, there's not a good place to be it. So I was up for a penalty. It's what they're doing that, you know, that's part of the problem. But it was, but it was because of that comment that we ended up getting press coverage on it. And then the press then asked the IRS for comment, and then the IRS did comment, and we actually got clarity in that article. And it's unfortunate that they haven't issued the Brexit. I knew they weren't going to do it before the election, but it's, you know, I think one of the unfortunate things with proposed regulations is that there isn't any time requirement for when they need to finalize the regs. So we don't actually know when they're going to. I mean, I think given the volume of comments that were submitted, I think they are going to submit a final reg, but we just don't know when. But with that particular campaign, I had no idea. We did our initial email blast just to the people signed up to the Taxation Task Force mailing list. And we got like hundreds of people. And I was just like, whoa, this is a lot bigger than I thought it was. I knew about it, but I didn't know how big of a problem it was for people. So I then went and did further investigation talking to our different country committees, asking them like, is this a problem in your country and your country? And like, it just became really clear. It's the biggest problem in Canada with the tax-free savings account in the UK with the self-invested pension, the SIP, and Australia with the superannulation. Yeah, it's a problem for anybody trying to base their financial and retirement planning. I'm a tax legislation. I'm another country, basically. Well, it's not so much of a problem. I mean, there are other countries which are impacted on it, but those three countries, by far, are the most impacted. But that brings us into the hole because where goes the 35, 20, in many cases, so goes the PFIC issue, right? They tend to be linked. Yeah. Yeah. And so, like, I would really recommend anybody that listens to this, please go and submit your comment on the PFIC form, which is open right now and it closes on November 19th. I haven't been as loud about it because of the, to be honest, I don't think very many people would see it because of all of the election coverage. But from November 6th, we're planning on really hammering people the last two weeks to get people to submit their comments on it because they're, again, the more, and just so that, you know, this form comes up for renewal every two years. And two years ago, there was one comment submitted. I'm not at all surprised by that because I've been, you know, working on putting something together on that. And I haven't written, you know, many years ago, I wrote something that really substantial on the pit. Usually I write these things by the way to figure them out myself. Okay. That's how I learned. You know, basically, I mean, and now, you know, I know a lot more about it. And that's the good news. The bad news is that it's even more incomprehensible than I thought, you know, years ago. Yeah. I'll definitely share with you our draft comment on it when I'm confident about sharing it. But it's the, the PFIC one is even more of a like, it's, it's blowing my mind on how it's basically next to impossible for anybody to actually feel like nobody can fill it out themselves. It's just, yeah, it's, it's crazy. That's the first problem. The second problem is the most tech professionals can't either. Okay. You know, it's, it's just so totally crazy. But so the solution that it seems to me is very similar to the solution on the 3520 thing. I mean, yeah, it actually is. The exemption to weigh over 25,000. And the second is the need to exclude mutual funds held in certain kinds of retirements accounts from reporting. I mean, it seems to me that there's your answer. The problem is not the comments about right. It's about the form. So the question is, how do you link those two issues? Well, I think this is where, you know, with the, with the 3520 campaign, it was just about the reporting requirement of the, of the foreign trust. What the IRS made really clear to us is that that was not about the definition of a foreign trust, which is where they were, they wouldn't even admit that a pension wasn't a foreign trust. Like a non-US pension was, was not foreign trust. Like it wasn't even about that. But I think it's, it's really about, and this is really where it comes down to strategy, right? In terms of leveraging on these opportunities where there's an open door with the IRS or treasury, where they're seeking comments in order to make the bigger point that Americans abroad should not be having to file that form or, you know, just making it really obvious how difficult it is to, to comply or understand and the cost and the penalty. Like all, all of that combined together, just, it makes it really obvious how difficult a CBT system is to administer. So like, it helps our advocacy in terms of making it so much easier to sell and get people on board with RBT. We better able to identify, you know, to define it as a huge problem. You know, I think really, clearly it has that effect. Of course, you would agree that the things we're talking about are more regulatory than legislative issues. Yeah, but I mean, I, I, I share all this stuff with our congressional contacts because ultimately, it's, it's Congress who has the, like, Congress tells the IRS what to do. You know, not the other. That's a problem. And why? Yeah. And, and so they're, they're able to help us out by having additional conversations with the IRS and treasury about these, these difficulties, you know. All right. So, you know, let's go back to, you know, your words a few minutes ago about, you know, coming under criticism, you know, I think with respect to goals, purpose, etc. So I wonder, I'd like to invite you to, you know, so what is the goal of the, of the Democrats, a broad taxation tax force? What's the end game here? Well, I mean, the, I wasn't around when it was set up, but it, it was initially to address, I think it was originally the fat cut task force, I think originally, and then once things got more complicated, it then expanded to the taxation task force. So, so all the different areas, it's looking at reforming the, the tax, the US tax code in order to help Americans abroad. And there are a lot of different solutions on the table in order to make that happen. Residency based taxation is one of them. Sorry. What in your view would be sort of, you know, the end game, the ultimate solution? I mean, all of these things, you know, I mean, I agree with you that all of these things, you know, play a role, right? Presumably, well, I'll ask you, would you agree that the gold standard in terms of the solution is ending citizenship taxation, ending, ending the legislative right of the United States to impose people solely because of their citizenship for the full force of the internal revenue code. Yeah, but it's, that's, that's a big one to make. I mean, that would require a huge overhaul of the, the tax code, which, I mean, they, they only pass, there are very few tax bills that actually go through. So there's, there's what we want, and then there's the, the congressional reality, you know, and it's that ability to read the room, because look, let's be clear. Congress wants to help us, you know, Congress is keen to help out, but like, in one of the congressional meetings that we had, they even said that like, given how partisan the, the current Congress has been like, they, like, they can't even like, agree that puppies are cute. Like, that's how bad it is, right? And so you look at the people who are working in Congress, and they can't even agree that puppies are cute. Like, how are they going to pass RBT? I mean, it like, a lot of people are, and this is congressional staff are, really want to help us, but we need to go in with, we need to read the room and also like, go in with an ask that it is understanding of the current congressional makeup and also what is achievable. So I've, in this particular, Congress had focused on areas where I think that we can get some wins so that we can start providing relief for people sooner rather than later. And I don't think that that can all be achieved solely from residency-based taxation. I think that that is one of the bigger ones that would solve it for most people, most long-term Americans living overseas, especially for those that don't plan on moving back to the US. But then there are people that do plan on moving back. And also there are, you know, people still have their assets inside of the United States and will continue to be impacted by the IRS administratively or regulations or what have you. So it's a combination of lots of different areas, not just passing laws. So I don't know if that helps clarify. Do you see this as a partisan issue? No, it's really nonpartisan. It's framed sort of in the world of social media and that is a partisan issue. Who's done that? No, I'm just asking you if you think that it has been, you know, if it's sort of a Republicans versus Democrats or this versus that. No, I mean, look, everything gets tense around election time, right? But I mean, I think one of the advantages that we have on this particular issue is that it's really non-partisan, like everybody's on the same page about what the problems are. I think there's difference in terms of what the solutions are. I think that that's what it comes down to. But to be honest, that's no different from any other advocacy issue. I mean, you look at like gun reform or abortion rights, those are very partisan issues, right? Whereas with our tax issues, pretty much all Americans abroad are pretty much on the same page, you know, like we know what we want. A good thing, right, in terms of harnessing support for 100 percent. Yeah. Yeah. You know, we've got an election next week and, you know, then sort of back to more normal. And I know you're leaving the TAP group, but you're staying on with the DA task words. What is your goal or your vision for the DA task for saying the next year or whatever? Well, I didn't realize it at the time, but I think the last three years have been laying the groundwork for next year, because what we're hearing is that next year, there's going to be a big tax bill. It doesn't matter who wins the election, there's a lot of tax provisions we're expiring. And multiple offices, when we met with, we did our congressional visit that we call a doorknock in September. And multiple offices were telling us that they're calling it the Super Bowl of taxes next year, you know. So we're gearing up for next year, like we're gearing up for a win, I mean, we're gearing up for multiple wins, hopefully. And I think that, look, my kind of strategy has been, I'm going to bet on a bunch of horses, and hopefully one of them will win. So we have the, you know, maybe we might have some sort of legislative fix for the, not the 3524, but for getting pensions recognized as actual pensions and not as a foreign trust, we might have some legislative solutions. Like we have the buyer bill, the tax simplification for Americans abroad bill. There's also been another bill that's been in development, but hasn't been introduced yet. There's like multiple kind of avenues of actual legislation that I think that have a good chance of getting in. It's just a matter of being at the table at the right time. And a lot of the feedback we got when we were there in September, and that I continue to get as I continue to do calls, you know, us as a team, do calls, and also email with congressional offices on an ongoing basis to remind them that we exist, and to make sure that we have a seat at the table when the door opens on the big tax bill next year. Because I think that's where we've really missed out on opportunities in the past where it's not like you can just go once a year and do a door knock, and then you're like, it's an ongoing conversation that you need to continuously remind them, because it's doubly hard for us, because we're not actually in the country, right? Like it's even more difficult. And also like even some congressional offices we go and we meet with, they don't even know that they have constituents overseas, like, and these are individual staff that we meet with, like some of them haven't even traveled abroad. So it's a real uphill battle on multiple fronts, but it's not impossible. But this is the main thing is like, we've done a really good job, especially on the Democratic side, especially with those on the Ways and Means Committee, which is the Tax Writing Committee in the House. It hasn't been as easy with the Senate Finance Committee, but they definitely know us, and they know what we want. So I think that there's some good potential there for next year as well. So we'll kind of have to see, but we're going to be there, like, I'm even looking at going in January, like right when they start to make sure that, to remind them that we're here, that we still want to be part of the conversation, we still want our bills to be included. Absolutely. Well, Rebecca, this has been fascinating, and, you know, time has really gone by quickly. Probably should begin to bring this to a close, at least for today, but I'd like to give you the opportunity to say what you'd like to say, you know, anything you feel you have instead, or a message that people remember, or, you know, all the above, or some of the above, or whatever? I think one of the other things I've gotten criticism on is that people saying that, like, our, our, sorry. No, anybody who tries to do anything is going to get criticism. Okay, you know, I know, I know, but I think it's important. Personally, okay. No, I don't. I think it's important for people to understand the strategic decisions, like, as they as they should, because it may not necessarily always look like it makes sense if you if you're not involved, but, like, so one of the criticisms is that we're advocating for easier compliance or reinforcing CBT. And I really just want to kind of make it clear that, like, our BT is going to happen. It's just not going to happen tomorrow. And with as dysfunctional as Congress is, it's hard to get them on board with it. So I'm really trying to help people who are suffering today. So that's why we're advocating for interim solutions. But at the same time, it's helping get to our BT. And also, like, that means advocating for equivalent support that state-side Americans get for Americans abroad so that people aren't having to bile and paying extortionate ex-pat-tax specialists just to prove they owe no US tax, and also, like, reducing or eliminating unnecessary international information reporting and, you know, stuff like that. So, like, I just am trying to provide relief sooner rather than later for people. But it's not reinforcing CBT by any means. It's really, and it's working, to be honest, because, like, we're going into congressional meetings and people know us. Like, it's not like we're having to do, "Oh, we're Democrats abroad and we do blah, blah, blah." Like, we're picking, like, we're going and doing meetings in person because in-person meetings help. But on top of that, it's helping to put the pressure on Congress to move on this stuff. So I'm really looking at getting more people on board. So if there are any Democrats listening to this that want to join the team for next year and help us out with the Super Bowl of taxes and make sure that we get wins for Americans abroad in there, you're very welcome to reach out. I'm very happy to have you join the team. How would they reach out to you and where would they go? I can, well, the taxation TF at democratsabroad.org is our main email address, and I have a volunteer on boarding process. But, like, we're going to need more people, basically, to really help get this over the line. All right, well, that's great. And now you said something that made me curious, but didn't want to interrupt you. How much are people paying in London to get their taxes done every year? It varies. I mean, I hear from people who say they're spending thousands. And I actually, like, for a while, when I was getting an email from somebody who said that they were going to renounce over the taxes, I don't think people should be having to choose between keeping their US citizenship and being able to maintain tax compliance. Like, it's just ridiculous, right? At the present time, there are people who are in that position. Yeah, like most people that are renouncing, I would say, are renouncing over the tax problems, right? Yeah, even when they don't owe US tax. Yeah, I mean, I know a lot of people renounce because they're going to face some sort of big tax bill later down the line. But people are also looking at the annual, like if they're spending every year, thousands of dollars to prove they owe no US tax, that in and of itself is, you know, a cost, a lifelong cost. That's how they're looking at it. But what I started doing was, for a while, if somebody said, oh, I'm going to renounce, I would offer to do a call. Not everybody picked up on it. But I'd say probably about, I did probably around 10 calls. And a lot of it came down to lack of education or understanding. And like nine out of 10 people, I was able to talk them through a way for them to either save money or like some people didn't even know like half of their tax compliance costs were because of their P fix. And I was like, well, if you just get out of the P fix, then you don't have to pay half of that cost. And you know, stuff like that, I think there's a lot of lack of education in like people understanding how things work. And it's not their fault. It's not, you know, it's not easy to understand. But as a general principle, that the people who are renouncing are not renouncing, they're not renouncing because they don't want to be American citizens. They're renouncing because the conditions for remaining American citizens, they just can't meet. Yeah. And I, this was one of the points I was making in our recent congressional meetings is that they're, you know, the renunciation fee is going to drop soon. I don't know when but soon. And I've just really emphasized that there's going to be a tsunami wave of renunciations and. Yeah. Yeah. And we really need, I was trying to get Congress to do something, you know, to demonstrate that they are listening to us, they are paying attention. I think that has come out during the election, though, not like it did come out with the direct file letter, like, I don't dismiss the fact that we have 57 members of Congress on the record recognizing that 80% of Americans who file from abroad have an AGI of 100,000 and less, like, getting over this whole, like, we're all rich. Yeah, that's really, especially if living outside. That's monumental. That's, you know, groundbreaking. And we'll be using that for our ongoing congressional outreach, because we have 57 members of Congress on the record recognizing the tax problems of Americans abroad. Yeah. Well, that's interesting. All right. Well, you probably should bring us a close, at least for today. This has been a great conversation and. Yeah, thank you, John. Take the time and hopefully we can do this again. And as well as thank you for the conversation, I want to thank you for, you know, a tremendous effort that you put in for Americans abroad. Most of it, I'm sure, is basically thankless, because I know how much work it is. And, you know, after the election, I want you to slow down, you know, have a nice Christmas and relax a little bit, Rebecca. Yeah, I will be, but I'm going to be hitting the pavement pretty quickly in January, that's for sure, because it's too much, too much, you know, I know, I know. That's great. Well, thanks a lot. And let's connect again soon. Thanks, John.
