Commentators may be misreading the motivation for H.R.4501
It’s human nature to view and interpret the world based on our own experiences. Therefore, many Americans abroad (and their advocacy groups) interpreted the Hurd bill H.R.4501 as a sign that Congressman Hurd recognized the problems of citizenship taxation. This may not have been true. I now believe that H.R.4501 may have been an attempt to exempt one specific American citizen from U.S. taxation.
This is my third post commenting on Congressman Hurd’s H.R.4501. The first two posts are here and here:
Part 1: Colorado Congressman Jeff Hurd Recognizes Problems Of U.S. Citizenship Taxation
Part 2: The Hurd Bill – H.R. 4501 Does NOT Protect Pope Leo From FBAR (And FATCA) Reporting
Because Pope Leo is a overseas U.S. citizen, I (and many others) had reflexively assumed that H.R.4501 was motivated by an awareness of U.S. citizenship taxation. To put it another way:
I and others had confused the circumstance of Pope Leo being an overseas citizen with the motivation for H.R.4501. Upon reflection, I now believe that H.R.4501 was irrelevant to Pope Leo’s circumstance of being an overseas citizen.
My reasons are two-fold:
1. H.R. 4501 proposes to exempt Pope Leo from U.S. taxation on ALL income.
H.R.4501 does NOT exempt the Pope from ONLY non-U.S. source income. In addition (and this is key) H.R.4501 does NOT exempt the Pope from the information returns required by Subtitle F. (The information reporting is arguably the biggest problem for Americans abroad.)
2. Congressman Hurd’s statements when introducing H.R. 4501 focus on the importance of Pope Leo and do NOT refer to the circumstance of Pope Leo being an overseas citizen. In fact it made NO reference to Americans abroad.
Rep. Hurd Introduces Holy Sovereignty Protection Act to Safeguard Citizenship for American Popes
July 18, 2025
Press ReleaseWASHINGTON, D.C. — Today, Congressman Jeff Hurd (CO-03) introduced the Holy Sovereignty Protection Act (H.R. 4501), legislation to protect the U.S. citizenship of any American elected to serve as the Supreme Pontiff of the Roman Catholic Church. The bill prohibits the revocation of citizenship during a papal tenure and exempts the individual from U.S. tax obligations while serving as pope, recognizing his unique role as both a religious leader and head of state.
“The election of Pope Leo XIV marks a historic moment not only for the Catholic Church but for America,” said Rep. Hurd. “This legislation ensures that any American who answers the call to lead more than a billion Catholics worldwide can do so without risking his citizenship or facing unnecessary tax burdens. This legislation recognizes the extraordinary nature of the papacy—a role at the intersection of faith, leadership, and global responsibility.”
Q. Would President Trump’s pledge to end the double taxation of Americans abroad have the effect of exempting Pope Leo from all U.S.income taxation?
A. No (he would still be subject to U.S. taxation on U.S. source income)
Q. Would the LaHood bill proposing elective residency-based taxation for overseas Americans exempt Pope Leo from all U.S. taxation?
A. No (he would still be subject to U.S. taxation on U.S. source income)
Nevertheless, Pope Leo is an overseas American. I suspect that H.R.4501 will NOT become law. That said, how the U.S. citizenship tax regime applies to Pope Leo as an American abroad, will continue to raise awareness of citizenship taxation!
John Richardson – Follow me on X.com @ExpatriationLaw