Unmasking the Saving Clause: Why Americans Abroad Face Guaranteed Double Taxation

Tim Symthe - @TpSmyth01David Bindel - @DavidBindelTxDr. Suzanne DeTreville - @SDeTrevilleJohn Richardson - Expatriation Law This podcast is largely based on a post that appeared on the SEAT site at:https://seatnow.org/2025/10/06/a-simple-and-unilateral-treaty-fix-for-citizenship-taxation-richardson-snyder-and-alpert/“This episode examines the U.S. tax treaty “saving clause,” which lets the United States deny treaty residency tiebreaker benefits to U.S. citizens and effectively causes double taxation for Americans living abroad.Speakers discuss history, practical harms (FBAR, pensions, capital gains), and a proposed executive-branch remedy: simply choosing not to invoke the saving clause so expats can rely on treaty tiebreakers, plus legal and durability considerations.” This is a public episode. If you would like to discuss this with other subscribers or get access to bonus episodes, visit expatriationlaw.substack.com