This One Hits Close to Home
Over the past few years, I went through the long (and honestly, emotional) process of having my Italian citizenship recognized through jure sanguinis—citizenship by descent. It was something I’d been working toward for years, and finally receiving confirmation from Italy was incredibly meaningful. My great-grandparents immigrated from Abruzzo, so gaining dual citizenship felt like closing a family history loop. You can read more about my process here.
So when Senator Bernie Moreno (R-OH) introduced the Exclusive Citizenship Act of 2025, a bill that would ban dual citizenship for all U.S. citizens, it naturally caught my attention—not only personally, but professionally.
Dual citizenship isn’t just a cultural topic, it’s a tax topic, especially in a country like the United States where taxation is tied to citizenship, not residency.
Let’s break down what’s in the bill, why it matters, and how it could affect taxpayers—especially dual citizens and the Accidental American community.
What the Bill Actually Says About Dual Citizenship
The bill is surprisingly short and direct. Here’s the key language:
“An individual may not be a citizen or national of the United States while simultaneously possessing any foreign citizenship.”
— Exclusive Citizenship Act of 2025
If the bill passed:
- Dual citizenship would be illegal.
- Anyone who gains foreign citizenship in the future is automatically deemed to have relinquished U.S. citizenship.
- Existing dual citizens get one year to choose which citizenship to keep.
- Failure to choose means the U.S. treats you as having voluntarily relinquished U.S. citizenship.
That “voluntarily” phrasing is extremely relevant for taxes…
Why This Citizenship Issue Matters for Taxes
The U.S. is one of the only countries on Earth that taxes based on citizenship rather than residency (Eritrea being the other one). That means:
- You owe U.S. taxes even if you live permanently abroad.
- You must report foreign bank accounts.
- FATCA compliance follows you everywhere.
- Foreign financial institutions often refuse accounts to U.S. citizens.
This system impacts many groups:
- U.S. expats
- People married to foreign nationals
- “Global nomads”
- Accidental Americans (people who were born in the U.S. but spent their entire lives elsewhere)
A law that bans dual citizenship would immediately collide with FATCA, citizenship-based taxation, and the Exit Tax regime.
The Big Question: Would Choosing Another Citizenship Trigger the Exit Tax?
Short answer: Almost certainly yes.
Longer explanation:
IRC §877A (Exit Tax) applies if someone:
- Voluntarily gives up U.S. citizenship, and
- Meets the definition of a covered expatriate, based on:
- net worth
- average annual income tax liability
- or failure to certify 5 years of tax compliance
The bill’s language is designed to meet that definition.
It explicitly states that not renouncing a foreign citizenship within 1 year means the person is:
“deemed to have voluntarily relinquished United States citizenship.”
That’s the exact phrase that triggers Exit Tax consequences.
Meaning:
✔ Covered expatriates would owe Exit Tax.
✔ Accidental Americans would still face filing burdens.
✔ Renunciation would still require Form 8854 and IRS compliance.
✔ There is no escape hatch in the current draft.
Unless Congress amends §877A, dual citizens forced to choose would not be exempt from the Exit Tax.
This is why the bill is not simply an “immigration bill.” It’s indirectly a tax bill, whether intended or not.
“Decision Tree: If Dual Citizenship Becomes Illegal, What Happens?”
- Are you a dual citizen today?
• YES → Choose within 1 year:- Renounce foreign citizenship → Remain U.S. citizen
- Renounce U.S. citizenship → Possible Exit Tax
- Fail to choose → U.S. treats it as voluntary expatriation (Exit Tax triggers)
- Are you planning to seek foreign citizenship?
• YES → Gaining it = automatic loss of U.S. citizenship
• No opportunity to maintain dual status
What About Accidental Americans?
Accidental Americans already face some of the harshest consequences of U.S. citizenship:
- They often owe zero tax but have enormous filing burdens.
- They struggle to open foreign bank accounts because of FATCA.
- Many want to give up U.S. citizenship but can’t afford the compliance cost.
This bill doesn’t resolve any of that.
If anything, it may increase the urgency—and the cost—of renouncing.
International and Constitutional Issues (Short Version)
A few practical considerations:
1. Constitutional concerns
The U.S. Constitution recognizes citizenship rights that Congress cannot easily revoke. Courts may block automatic denationalization.
2. Millions of U.S. dual citizens exist today
Mexican-American, Canadian-American, Israeli-American, Irish-American, Italian-American, and Indian-American communities are huge. Requiring millions of people to file renunciations in one year is logistically impossible.
3. FATCA treaties were built assuming dual citizenship exists
Dozens of international agreements would need renegotiation.
In other words: even if this bill moves forward, its implementation would be messy and slow.
Q&A Section
Q: Should dual citizens panic?
A: No. This is an early-stage proposal. Nothing is happening right now.
Q: Does this affect people who recently received dual citizenship (like my Italian citizenship)?
A: If the bill passed as written, yes—you would eventually have to choose. But again, passage is unlikely in its current form.
Q: Would I owe the Exit Tax if I had to choose the foreign citizenship?
A: Under the current bill language: yes, likely.
The IRS will treat it as voluntary expatriation.
Q: Could Congress write an exception into the tax code?
A: They could, but the current bill doesn’t attempt it.
Q: Could the bill be struck down by the courts?
A: Very possible. Automatic loss of citizenship raises major constitutional issues.
Final Thoughts
This bill may not move forward as written, but it highlights an important truth:
The U.S. citizenship-based tax system creates real hardships for Americans living abroad and dual citizens.
Whether this bill goes anywhere or not, Congress is clearly hearing pressure—especially from the expat and Accidental American communities.
I’ll be watching this legislation as it evolves, particularly any amendments relating to:
- FATCA
- Exit Tax exceptions
- Special relief for existing dual citizens
- Administrative procedures for renunciation
And for anyone with dual citizenship—or anyone considering it—now is a good time to start paying attention.
If you’d like some additional reading on this proposed legistion, here are a few resources to get you started:
- Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship
- Ohio senator introduces measure to eliminate dual citizenship
- Ohio senator introduces bill that would eliminate dual citizenship
- Senator Bernie Moreno of Ohio has introduced a bill to eliminate dual citizenship for Americans
If you want updates, I’ll post them as soon as more information is available.