The Essential Tax Podcast with Mishkin Santa, Season 3, Episode 4

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Erik Sansen, Founding Partner and Attorney at Sansen International Tax Lawyers, a Belgian boutique law firm specializing in international tax law. After a career of many years in international law firms, Erik founded Sansen International Tax Lawyers in 2014. Erik’s practice focuses on assisting emigrating or immigrating taxpayers, investors, entrepreneurs, and companies with the local and global realization of their investments and plans.

Tune in for these key takeaways:

• Conversation around why Belgium has historically been an attractive option for private investors and globally mobile families, and recent tax law changes that may affect this desirability.

• A brief introduction to Belgian tax residency rules, requirements, and potential pitfalls for incoming taxpayers.

• Discussion about when the Belgian tax system might become relevant for US persons and their advisors, whether it be through relocation, investment holdings, succession, or business entities.

• Dialogue surrounding how Belgium views and taxes atypical investment concepts from the US (Roth IRA, S-Corp interests, short-term capital gains, etc.)

• Tips for developing an effective gift and estate planning strategy in Belgium.

• A high-level overview of concepts relevant to pre-immigration tax planning for a taxpayer inbound into Belgium, such as asset moves, liquidity events, reorganizations, tax residency, dual residency risk, and exit taxation.

Learn more about Erik Sansen:

• Visit the Home page on Sansen International Tax Lawyers’ website: https://sanseninternational.tax/nl

• View Erik Sansen’s profile on Sansen International Tax Lawyers’ website: https://sanseninternational.tax/en/over-ons

• Connect with Erik on LinkedIn: https://www.linkedin.com/in/sanseninternationaltaxlawyers/

• Follow Sansen International Tax Lawyers on LinkedIn: https://www.linkedin.com/company/sansen-international-tax/posts/

• Email Erik directly: erik@sanseninternational.tax

Further Resources:Sansen International Tax Lawyers - Digital Brochure***********************************

About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax—all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 3, Episode 3

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Nadine Anderson, Associate, Wolf Theiss. Nadine is an immigration attorney that holds degrees in both business law and finance. She began her career focusing on tax law but quickly shifted to immigration as a primary focus. Wolf Theiss was founded in 1957, is the largest law firm in Austria, and one of the leading law firms in Central, Eastern and South-Eastern Europe.

Tune in for these key takeaways:

• An update on the current status of global mobility trends Austria in 2026 and the recent influx of inbound taxpayers coming to Austria from the US.

• Elaboration regarding Section 10(6) of the Austrian Citizenship Act, which contains a citizenship by merit provision.

• Discussion of the provisions of the Austrian Citizenship Act, Section 58(C), which provides restitution to victims of Nazi victims and their descendants.

• Dialogue surrounding Austria’s current prohibitions of dual citizenship.

• A discussion of the income and transfer tax implications of obtaining Austrian Citizenship, from a tax perspective.

• Conversation on generally recommended pre-immigration tax planning strategies for individuals moving inbound into Austria.

Learn more about Nadine Anderson:

• Visit the Insights page on Wolf Theiss’s website: https://www.wolftheiss.com/insights/

• View Nadine’s profile on Wolf Theiss’s website: https://www.wolftheiss.com/lawyer/nadine-anderson/

• Connect with Nadine on LinkedIn: https://www.linkedin.com/in/nadine-anderson-b19706159/

• Follow Wolf Theiss on LinkedIn: https://www.linkedin.com/company/wolf-theiss/

• Visit Wolf Theiss’s YouTube Channel: https://www.youtube.com/@wolftheissrechtsanwalte

• Follow Wolf Theiss on Facebook: https://www.facebook.com/WOLFTHEISS

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 3, Episode 2

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Mary Beth Lougen, EA, USTCP. Mary Beth is the President and Founder of American Expat Tax Services, which is an international tax preparation firm that assists Americans living abroad. She is also the COO of Expat Tax Tools, an international tax software company. She has over 35 years’ experience in the International Tax Industry.

Tune in for these key takeaways:

• A brief history of the PFIC (Passive Foreign Investment Company), including information about what a PFIC is, how the US tax system handles it, and how the laws surrounding them have evolved over time as the international world has become more interconnected.

• How and when a REIT (Real Estate Investment Trust) would be considered a PFIC under the Internal Revenue Code.

• Why US PFIC rules exist and how best to navigate them and stay in compliance if you find yourself owning a PFIC.

• A discussion of what to do if you find yourself out of compliance with PFIC rules, what the IRS penalties are for noncompliance, and how best to minimize these types of penalties over time.

• An outline of different types of elections, purge scenarios, and IRS Private Letter Rulings that can be used to minimize PFIC tax burden, and when they might be applicable.

• When a Check-the-Box Election might apply to a PFIC and how it affects all shareholders in a CFC (controlled foreign corporation).

Learn more about Mary Beth Lougen:

• Explore the Form 8621 Calculator on Expat Tax Tools’ website: https://form8621.com/

• View Mary Beth’s profile on Expat Tax Tools’ website: https://expattaxtools.com/our-team/#to-beth-intro

• Connect with Mary Beth on LinkedIn: https://www.linkedin.com/in/bethlougen/

• Follow Expat Tax Tools on LinkedIn: https://www.linkedin.com/company/expat-tax-tools/

• Visit Expat Tax Tools’ YouTube Channel: https://www.youtube.com/@expattaxtools9362

• Follow Expat Tax Tools on Facebook: https://www.facebook.com/TaxTools

• Email or Call Mary Beth directly: 6136918621, ext. 1

Further Resources:

• Mary Beth’s Article in CPA Practice Advisor - “Form 8621 Non-Filing Risk: Why PFIC Compliance Deserves More Attention”: https://www.cpapracticeadvisor.com/2026/05/19/form-8621-non-filing-risk-why-pfic-compliance-deserves-more-attention/183576/

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa

Season 3, Episode 1

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with John P. Dedon, Of Counsel, Cameron Ingersoll Roche PLLC. John is a tax lawyer with a talent for explaining the complexities of tax law in lay terms. He has focused his practice on estate planning, asset protection, Trusts, and other business areas for more than 35 years.

Tune in for these key takeaways:

• A brief history of estate tax in the United States and discussion of the current state of affairs, both federally and in the few individual states that impose estate tax on their citizens.

• For spouses, the importance of claiming a Portability Exemption in estate planning.

• An examination of the relationship between estate tax and net worth.

• How to address issues of incapacity that may arise when preparing an estate plan, and critical documentation to include in your plan.

• An outline of the requirements for an effective Trust, Living Will, Power of Attorney, and Advanced Medical Directive.

• A discussion of the benefits of a Living Will and Revocable Living Trust, and how they work in tandem to provide asset protection and continuity of wealth upon death.

• A discussion of the pitfalls of Transfer on Death and Beneficiary accounts, and how to ensure these assets are included in an all-encompassing estate plan.

• A brief overview of how and with what level of scrutiny Public Charities and/or Private Foundations are currently taxed.

Learn more about John P. Dedon:

• Visit John’s Blog at: https://www.dedononestateplanning.com/

• View John’s profile on Cameron Ingersoll Roche PLLC’s website: https://cirlaw.com/attorney/john-p-dedon/

• Connect with John on LinkedIn: https://www.linkedin.com/in/john-dedon-a191a46/

• Follow Cameron Ingersoll Roche PLLC on LinkedIn: https://www.linkedin.com/company/cameron-ingersoll-roche-pllc/

• Follow Cameron Ingersoll Roche PLLC on Facebook: https://www.facebook.com/CameronMcEvoyPllc

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to help understand complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 18

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Rebecca Mowat, Senior Partnerships Director, Currencies Direct. Currencies direct was established in 1996 and is headquartered in London, England. Rebecca is a transatlantic business leader specializing in partnerships and business development. She has over 20 years’ experience helping UK and US companies expand internationally. She originally came to the US via A2 Diplomat Visa while employed by the British government. She is currently based in Atlanta, Georgia.

Tune in for these key takeaways:

• A discussion of how Currencies Direct can assist US individuals and businesses both domestic and abroad in minimizing financial losses due to exchange rates and simplifying the process of managing multiple international currencies.

• Insight into Executive Order 14247: Modernizing Payments To and From America’s Bank Account

• Information on how Currencies Direct can help a US or non-US person that does not have a US bank account to obtain a direct deposit for their IRS refund now that the IRS has ceased issuing paper checks for refunds.

• Information on how Currencies Direct can help a US or non-US person to submit an electronic payment to the IRS once the IRS implements their new protocol of only accepting payments via electronic methods.

• A discussion of different approaches to avoid some of the lengthy pitfalls surrounding giving and receiving FIRPTA payments.

• Information about the applicability of Currencies Direct’s accounts to unique structures like non-US trusts and Australian Superannuation Funds.

Learn more about Rebecca Mowat & Currencies Direct:

• Connect with Rebecca on LinkedIn: https://www.linkedin.com/in/rebecca-mowat-2401602/

• Visit the FIRPTA page on Currencies Direct’s website: https://www.currenciesdirect.com/en-us/firpta

• Follow Currencies Direct on LinkedIn: https://www.linkedin.com/company/currencies-direct/

• Follow Currencies Direct on Facebook: https://www.facebook.com/currenciesdirect

• Register for a no-fee Account & Preferential Rates with Currencies Direct: https://www.currenciesdirect.com/en-gb?afflno=0202110000823909&assetid=0000108

• Book a 30min Partnerships Meeting with Rebecca: https://calendly.com/rebecca-mowat/30min

Further Resources:

• Link to Fact Sheet 2026-02: https://www.irs.gov/pub/taxpros/fs-2026-02.pdf

• Link to the Executive Order: https://www.whitehouse.gov/presidential-actions/2025/03/modernizing-payments-to-and-from-americas-bank-account/

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 17

In this episode of The Essential Tax Podcast, Mishkin Santa visits with attorney Becki L. Young, Partner, Grossman Young & Hammond. Becki was recently recognized by Business Today as one of the Top 10 Most Influential Business Lawyers in the USA. Mishkin and Becki discuss US immigration policies as they relate to incoming foreign nationals and outgoing American citizens. They also discuss current events in the US immigration sphere.

Tune in for these key takeaways:

• A discussion of the current landscape in the immigration arena for the path to US Citizenship, how it’s changed since January 2025, and where it might be heading for the future.

• Clarification regarding the physical presence and continuous residence requirements.

• How unresolved tax issues such as unpaid taxes, civil penalty disputes, and failure to timely file could affect a permanent resident application.

• Tips and best practices for applicants preparing for the citizenship application process.

• A timeline of the full US immigration & naturalization process and the various tests and requirements involved, as well as follow-up items to consider such as a US passport and naturalization certificate.

• Recent debate and changes to denaturalization and exit tax requirements.

• Opinions on the proposed “Exclusive Citizenship Act of 2025” introduced by Senator Bernie Moreno.

Learn more about Becki L. Young:

* Visit the Resources page on Grossman Young & Hammond’s website: https://www.grossmanyoung.com/resources/

* View Becki’s profile on Grossman Young & Hammond’s website: https://www.grossmanyoung.com/attorneys/becki-young/

* Connect with Becki on LinkedIn: https://www.linkedin.com/in/blyimmigration/

* Follow Grossman Young & Hammond, LLC on LinkedIn: https://www.linkedin.com/company/grossmanyoung/

* Visit Grossman Young & Hammond’s YouTube Channel: https://www.youtube.com/@grossmanyounghammondllc73

* Follow Grossman Young & Hammond, LLC on Facebook: https://www.facebook.com/grossmanyoung/

Further Resources:

• The proposed “Exclusive Citizenship Act of 2025” introduced by Senator Bernie Moreno: https://www.congress.gov/bill/119th-congress/senate-bill/3283

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 16

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Elizabeth McMorrow, JD, LL.M., owner at Elizabeth McMorrow Law, LLC. Prior to starting her law firm, Elizabeth served as in-house counsel at The Coca-Cola Company and Genzyme Corporation, a member of the Markit|CTI legal advisory team, a Senior Associate with Dewey Ballantine, and a clerk at the U.S. Court of International Trade.

Tune in for these key takeaways:

• A brief explanation and history of FATCA (Foreign Account Tax Compliance Act), CRS (Common Reporting Standard), and CARF (Crypto-Asset Reporting Framework).

• A discussion of the state of CARF and several theories and predictions on what may be in store for the future of CARF reporting.

• Insight into the current impact that FATCA has on US ex-pats.

• Dialogue around the duplicative nature of the FBAR and Form 8938 and possibilities for the future of these two reporting mechanisms.

• Common issues with the current impact of FATCA on banks, hedge funds, assets, trusts, and fund administrators.

• Discussion about current impact of CARF in the digital asset space.

An outline of situations where multi-jurisdictional reporting may be required and strategies for navigating.

Learn more about Elizabeth McMorrow:

• Visit the About page on Elizabeth McMorrow Law LLC’s website: https://www.elizabethmcmorrowlaw.com/biography

• Connect with Elizabeth McMorrow on LinkedIn: https://www.linkedin.com/in/elizabethmcmorrow/

• Peruse Elizabeth’s Blog Posts on Elizabeth McMorrow Law LLC’s website: https://www.elizabethmcmorrowlaw.com/blog

Further Resources:

• IRS Foreign Account Tax Compliance Guidance: https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca

• IRS Form 8938 Guidance: https://www.irs.gov/forms-pubs/about-form-8938

• FinCEN FBAR Guidance: https://www.fincen.gov/report-foreign-bank-and-financial-accounts

• White Paper: Who Reports Cryptocurrency to the IRS? - https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4261066

• 2025 White House Strengthening American Leadership in Digital Financial Technology - https://www.whitehouse.gov/wp-content/uploads/2025/07/digital-Assets-Report-EO14178.pdf

• 2025 Testimony of Lawrence Zlatkin, Vice President, Tax, Coinbase Global, Inc. - https://www.finance.senate.gov/imo/media/doc/100125_zlatkin_testimony.pdf

• Digital Asset PARTIY Act, U.S. Congressman Max Miller - https://maxmiller.house.gov/posts/congressman-max-miller-releases-bipartisan-legislation-to-modernize-tax-treatment-of-digital-assets

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 15

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with David Roche, JD. David is a practicing Attorney with KVS Title, LLC. He has been employed with KVS for 14 years and has been working in the business for 23+ years. He is extremely knowledgeable regarding FIRPTA requirements and processes.

Tune in for these key takeaways:

• A brief history of FIRPTA, who it applies to, and how it’s evolved since its inception in the 1980s.

• Some common myths and misnomers about the FIRPTA process and how to avoid pitfalls to make your FIRPTA transaction the most efficient possible.

• A summary of the options that real property buyers and sellers have regarding FIRPTA withholding and filing.

• A timeline for handling FIRPTA obligations with the IRS and insight into the IRS’s process for handling FIRPTA claims.

• A discussion of several common scenarios and challenges that a real estate buyer or seller might experience, and suggestions for the best ways to approach these scenarios.

• Clarification between a Social Security Number (SSN) and an Individual Taxpayer Identification Number (ITIN).

• When and why it may be necessary to employ both an attorney and a CPA to assist with FIRPTA transactions.

Learn more about David Roche:

• Visit the Our People page on KVS Title’s website: https://www.kvstitle.com/our-people

• Visit the KVS Title website: https://www.kvstitle.com/

• Follow KVS Title on Facebook: https://www.facebook.com/KVSTitle/

Further Resources:

• Visit The Wolf Group’s FIRPTA Tax Help Page: https://thewolfgroup.com/services/firpta-tax-help/

• Visit Congress.gov’s FIRPTA Page: https://www.congress.gov/crs-product/IF12498

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

• YouTube: https://www.youtube.com/@TheWolfGroupPC

• Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

• Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

• Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

• Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa