Part A – Introducing H.R. 4501

H.R.4501 – To protect the citizenship of, and provide tax-exempt status to, any American elected as the Supreme Pontiff of the Roman Catholic Church.

https://www.congress.gov/bill/119th-congress/house-bill/4501

Here is the text of the bill. It’s amazingly clear. It’s amazingly honest. It states that Subtitle A of the Internal Revenue Code will not apply to Pope Leo. It is certainly one of the most honest and clear carve outs I have ever seen. (Interestingly it would NOT exempt Pope Leo from subtitle F which contains the international information return reporting requirements.)

BILLS-119hr4501ih

Let’s break H.R.4501 down:

H.R.4501 – To protect the citizenship of, and provide tax-exempt status to, any American elected as the Supreme Pontiff of the Roman Catholic Church.

H.R.4501 – To 1. protect the citizenship of (U.S. citizens abroad are being forced to renounce U.S. citizenship because of citizenship taxation) , and 2. provide tax-exempt status to (end U.S. citizenship tax jurisdiction over), any 3. American (U.S. citizen and possibly resident) 4. elected as the Supreme Pontiff of the Roman Catholic Church (appears to condition the benefit based on religion – 14th Amendment issue?).

At present there is no more information on the government site.

Part B – The tax exemption directly implicates the issue of citizenship taxation

The Internal Revenue Code (see section 1) clearly states that U.S. citizens are subject to taxation on their worldwide income. Therefore, for Pope Leo to NOT be considered a U.S. tax resident either:

1. The Internal Revenue Code would require some kind of amendment. The amendment might be a move to “residence-based taxation” or a special carve out for Pope Leo. (An example of a special carve out might be: “Individual” does not include a U.S. citizen Pope”); or

2. It could be incorporated into “A Simple Regulatory Fix For Citizenship Taxation“.

The point is that NO MATTER how this would be achieved it WILL require a rethinking of “citizenship taxation”. It will also require ensuring (if this is even possible that the amendment meet constitutional standards).

Part C – The statement of Congressman Hurd

H.R.4501 was introduced by Congressman Jeff Hurd from Colorado. The wikipedia article describes Hurd as being Catholic (presumably explaining his interest in this issue).

Interestingly, Congressman Hurd’s wife (by her own admission) was born in Czechoslovakia and may be a Czech citizen. If so, this might mean that Congressman Hurd’s five children are (by birth or naturalization) dual U.S./Czech citizens.

Further commentary about the possibility of U.S./Slovokia dual citizenship is here and here.

A press release describing H.R.4501 on his site states:

Rep. Hurd Introduces Holy Sovereignty Protection Act to Safeguard Citizenship for American Popes

July 18, 2025
Press Release

WASHINGTON, 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.”

Significantly, the press release acknowledges Congressman Hurd’s belief and understanding that:

– certain activities can trigger the involuntary relinquishment of U.S. citizenship (not the case since the 1967 decision in Afroyim v. Rusk); and

– the problematic nature of U.S. citizenship taxation (specifically the imposition of U.S. worldwide taxation on U.S. citizens living outside the United States).

Part D – Why H.R.4501 is helpful to Americans abroad and the fight for residence-based taxation

The introduction of H.R. 4501 is a clear recognition that citizenship-based taxation presents unnecessary problems (and burdens) for Americans abroad. Although Congressman Hurd does NOT suggest that Americans abroad are renouncing their citizenship because of the U.S. extra-territorial regime, the quest to “Save The Pope” is a clear recognition of the problems caused by the exiting regime.

Given that H.R.4501 appears to provide a benefit based solely on affiliation with a specific religion, I suspect that it is dead on arrival. That said, it can (and should) be used to raise the question of why ANY U.S. citizen living outside the United States should be subject to the U.S. worldwide/extra-territorial taxation regime.

Specifically, H.R.4501 is support for both President Trump’s pledge to end the double taxation of Americans abroad and the LaHood bill which was introduced in December of 2018. I suggest that it be interpreted in this spirit.

Part E – What Americans abroad and their champions should do

This is simple. As a Catholic Congressman Hurd has an interest in maintaining the viability of a U.S. citizen Pope. As a father Congressman Hurd has an interesting in enhancing the life opportunities of his children to ensure that their life opportunities are not dampened by U.S. citizenship taxation.

I would reach out to Congressman Hurd and enlist his aid in supporting the ending of the double taxation of Americans abroad!

John Richardson – Follow me on X.com @ExpatriationLaw

Appendix

Here is a July 30, 2025 “X Spaces” discussion about the Hurd bill: