Tag Archives: Congressman Hurd

Part 3: The Hurd Bill – H.R. 4501 May Not Be Motivated By The Problems Of U.S. Citizenship Taxation And Americans Abroad

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


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Part 2: The Hurd Bill – H.R. 4501 Does NOT Protect Pope Leo From FBAR (And FATCA) Reporting

Part A – Purpose and Summary:

This is my second post on H.R. 4501. My first post was a general introduction and is here:

Colorado Congressman Jeff Hurd Recognizes Problems Of U.S. Citizenship Taxation

The purpose of this post is to argue that H.R.4501 does NOT protect U.S. citizen Pope Leo from the invasive reporting obligations which are at the heart of what it means to be a U.S. citizen. The Catholic Church may rue the day that it elected a U.S. citizen as pope.

To put it simply:

H.R.4501 exempts Pope Leo from Subtitle A of the Internal Revenue Code (the income tax). It does not:

1. Exempt him from Subtitle F – specifically Chapter 61 – which is where the penalty-laden information reporting requirements are found; and

2. It does not exempt him from section 5314 of 31 U.S.C. which is where the FBAR requirements are found.

For H.R. 4501 to achieve the tax and reporting related aspects of its legislative purpose it must:

– either exempt him from Subtitle F in addition to exempting him from Subtitle A or exempt him entirely from Title 26 (The Internal Revenue Code); AND

– exempt him from 5314 of 31 U.S.C.

This post is organized as follows:

Part A – Purpose and Summary:
Part B – The Concerns Articulated By Representatives Of The Catholic Church And Others
Part C – Parsing H.R.4501 – why it does NOT achieve what it purports to achieve:
Part D- An X.com thread discussing this issue …

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