Congress, Pope Leo XIV needs your help. So do the other 5 million other Americans abroad.

Dear Congress,

Imagine the Pope, seated in the Vatican, fulfilling his spiritual duties—while also being required to file a tax return with the IRS. That may sound absurd, but that’s the legal reality all Americans abroad face under the United States’ outdated policy of citizenship-based taxation.

On July 17, 2025, Representative Jeff Hurd (R–Colorado) introduced a new bill in Congress: the Holy Sovereignty Protection Act. Its purpose? To protect Pope Leo XIV, a U.S. citizen, from losing his citizenship or being subject to U.S. tax and other reporting obligations simply because he was elected to lead the Vatican. The bill would effectively exempt him from U.S. tax reporting requirements by applying Residence-Based Taxation (RBT)—a system where individuals are taxed based on where they live, not where they were born. 

This is a welcome move. But it raises a critical and obvious question:

What about the rest of us?

Congress should not only protect the first American pope. It should also intervene to help the more than 5 million other Americans living abroad and who suffer under the same system.

Tax Fairness or Americans Abroad fights for a fair and modern tax system that respects the lives and realities of all Americans who live, work, and raise families outside the United States. These citizens already pay taxes where they live. But under CBT and laws like FATCA, they are still required to file annual U.S. tax returns, report all their non-U.S. bank and retirement accounts, and often spend thousands in compliance costs. They also face disproportionate penalties for mistakes, however minor or un-intentional.

It doesn’t have to be this way.

Rep. LaHood’s solution

In December 2024, Rep. Darin LaHood (R–Illinois) introduced the Residence-Based Taxation for Americans Abroad Act. This bill would bring U.S. tax policy in line with virtually every other developed country by taxing citizens based on where they live—not their passport. The bill is designed to be bipartisan, because this is a bipartisan problem. The need for reform transcends party lines and affects real people across the political spectrum.

This issue is also on the political agenda. In October 2024, then-candidate Donald Trump pledged to end double taxation for Americans abroad “once and for all”. That pledge gave hope to millions of Americans who have long felt abandoned by both Congress and the White House. The time has come to act. The next Congressional elections are just a year off.

So, yes, please, fix the problem for the first American pope.  But please also fix it for the other 5 million-plus Americans abroad by adopting the Residence-Based Taxation for Americans Abroad Act. That would finally bring fairness, simplicity, and sanity to U.S. tax policy for Americans overseas. Including Pope Leo XIV.

Sincerely,

Tax Fairness for Americans Abroad

P.S. On Aug. 12, TFFAA sent a letter to Rep. Hood’s office encouraging him to support the LaHood bill and tax fairness for all Americans abroad in general. You can read our letter here.