Part A – Prologue – Citizenship And Residence Are NOT The Same
Circa – April 2017
In April of 2017 the Congress held a hearing to explore the unintended consequences of FATCA. Much has been written and discussed about that hearing at the Isaac Brock Society.
The panel was composed of both Republicans (anti-FATCA) and Democrats (pro-FATCA). The “ranking Democrat” was Gerry Connolly.
I was sitting at the back of the room. The hearing unfolded along the usual “party lines”. I have a very distinct memory of Gerry Connolly – in good faith – remarking that:
“All countries tax their citizens.”
Clearly Mr.Connolly was confusing “residents” with “citizens”. The inability to distinguish citizens from residents has made it harder to illuminate the problems of “citizenship taxation”.
Circa 2026 – LSAT Prep Coach Steve Schwartz
Yesterday, U.S. sanctions on Iran shut law school applicants out of their own LSAC accounts.
LSAC emailed them saying it’s prohibited from providing products or services to “Iranian citizens or residents,” and named LSAT registrations, CAS subscriptions, application processing, and reporting. Accounts went dark. Some of those people are days out from a scheduled test date.
Here’s the rule behind it.
On August 24, Treasury’s Office of Foreign Assets Control suspended Iran General License G indefinitely. That license is the reason American testing organizations could administer entrance exams to Iranians at all. Paragraph (b)(4) authorized U.S. persons “wherever located” to give university entrance examinations, including multiple choice standardized tests, to individuals “located in Iran or located outside Iran but who are ordinarily resident in Iran.”
The GRE and the TOEFL went first. The New York Times reported on September 1 that ETS canceled both in Iran, and that Duolingo pulled its English test for anyone who can’t register as a citizen of another country. The LSAT is the latest.
Now look at the wording.
The license turns on where you live. The email turns on citizenship. Those are not the same thing, and with Iran they’re really not. Under Article 976 of Iran’s Civil Code, anyone with an Iranian father is an Iranian national, born in Iran or not. Article 988 says giving it up takes being 25, completing military service, and getting the Council of Ministers to approve it. So someone born in the U.S. who has never set foot in Tehran holds a citizenship they can’t realistically drop, and LSAC’s own profile asks them to disclose it. The applicants who answered honestly are the ones who got locked out.
One private organization holds your test, your transcripts, your recommendation letters, and your applications. Its compliance team flips one switch and your whole cycle stops, over something you didn’t do.If you got that email, don’t wait it out. Applicants who wrote to Compliance@LSAC.org and returned the signed residence attestation with documentation are reporting their accounts restored, some the same night. Rolling admissions doesn’t pause while your file sits in a compliance queue.
JR Commentary: The observations of Mr. Schwartz capture the context of the problem. This is not necessarily an accurate description of the various laws and how they interact.
Part B – There is a difference between being a “resident” and being a “citizen”
The purpose of this post is to explore how confusing “citizenship” with “residency” can create significant and unanticipated problems for individuals simply trying to live their lives in the countries where they actually live.
The inability (or unwillingness) to distinguish citizenship from residence has resulted in a temporary prohibition on Iranian citizens resident in both Canada and the United States from taking the Law School Admission Test (“LSAT”). Clearly, it is important that the differences among the concepts of “residence”, “citizenship” and (I think) “domicile” be understand. A given person’s “residence”, “citizenship” and “domicile” may all be the same. On the other hand, a person’s “residence”, “citizenship” and “domicile” may all be different.
Part C – Heightened U.S. sanctions against Iran have caused this problem
For a more detailed understanding of how the U.S. sanction regime works in general see the Appendixes to this post which include:
Appendix A – The General Regulatory Framework Of Sanctions And Sanctions Against Iran
Appendix B – The August 24, 2026 End Of The Carve Out – Suspension of General License G
Appendix C – Educational Testing Service (“ETS”) Interpretative Statement and general page
Appendix D – How Law Services Interpreted The Sanction To Prohibit Iranian “Citizens” living in the United States and Canada From Taking The LSAT
Appendix E – Excellent Summary – from Military.com
Appendix F – Citizenship Law of Iran – Iranian citizenship is acquired by operation of law