American Citizens Abroad, Inc. (ACA) sees multiple paths to enact Residence-based taxation

Washington, D.C.
August 7, 2025

American Citizens Abroad, Inc. (ACA) sees multiple paths to enact Residence-based taxation

ACA is repositioning its advocacy strategy for Residence-based taxation (RBT), working with D.C.-based partners, lobbying and meeting directly with officials in Congress and the Administration to push forward on all legislative opportunities for RBT. RBT remains a top priority for ACA, and we see a number of legislative paths for getting RBT enacted. The House and Senate have both adjourned for the August district work period, but this does not mean that Congressional work on legislation is not happening, and ACA is there front and center. We see the following opportunities for continued engagement on tax policy priorities:

1. Government Funding Bill. Congress will need to approve a bill to fund the government by September 30th. Although not a tax bill, there is an opportunity for RBT to be rolled into a government funding the bill. The bill will need bi-partisan support, and RBT has support from both the Republicans and Democrats in the Congress.
2. Tax Reconciliation Bill. Speaker Johnson announced recently on “Sunday Morning Futures” that the Congress’ goal is to pass two to three additional reconciliation bills in this Congress. Similarly, Senate Finance Committee Chairman Mike Crapo recently said in an interview that his committee “didn’t clear the deck” on tax priorities in the first reconciliation bill and indicated there is demand for a second. These bills will not need bi-partisan support and would be passed under the same procedure as the One Big, Beautiful Bill Act (OBBB). Many Representatives in Congress did not get all their “tax requests” into the OBBB and they are lining up to push for more tax relief for their constituents. Much of this behind-the-scenes work will be done during the Congressional recess period and into the fall because the Republicans will push to pass as much of their tax agenda as they can before the midterms. RBT can benefit from this opportunity. Further, President Trump has yet to deliver on all his tax reform promises, and eliminating double taxation of U.S. citizens living and working overseas remains on the table. The Administration has a vested interest in fulfilling “promises made, promises kept.”
3. Bipartisan end of year deal. During consideration of OBBB, several policy items did not pass muster with the Senate’s Byrd Rule, some of which have bipartisan support. Congress may consider a bipartisan tax bill by the end of 2025, and in the House, Ways and Means Committee Jason Smith and Ranking Member Richie Neal have already met to discuss the possibility of a bipartisan, year-end tax package that Congress could consider. If Congress pursues this path, it provides another avenue for engagement on RBT.
4. Legislation addressing changes to visa and immigration, including Trump Gold Card. President Trump introduced a “Gold Card” visa program in February of this year. Details on this fast track to U.S. residency (and possible U.S. citizenship) for a $5 million price tag have been scarce. The latest information suggests that Gold Card will replace the EB-5 immigrant investor visa. Congress will need to approve any changes to visa and immigration programs, and for Gold Card to succeed it will need to exempt Gold Card holders from U.S. taxation on their foreign income. Statements from the Administration support the exemption from U.S. taxation on foreign income as they know it is key to the program.

ACA is investigating all these legislative opportunities. ACA management and our D.C. team will be working throughout the summer, visiting Congressional staff and the Administration to strongly advocate for RBT. Yes, Representatives will be back in their districts engaging with constituents, but their staffs in Washington continue to meet on these high priority policy issues. In fact, legislative aides have more time to discuss and explore policy when their bosses are out of D.C. and working in their legislative districts. ACA’s arguments for why RBT makes good sense for both individuals and for the economy continue to be the basis for our advocacy and they are well received in offices. New opportunities like Gold Card afford us even more reasons why RBT is needed for all U.S. citizens.

RBT excludes income earned outside the United States from U.S. taxation and, if an exclusion to taxing foreign income becomes part of a program for Gold Card investors, then RBT needs to be made available to U.S. citizens living and working abroad. U.S. citizens overseas already help create economic opportunities for the U.S. economy. There are hundreds of thousands of independent businesses run by Americans living abroad; with RBT there could be many more. The President already has a standing army ready and prepared to open doors to commercial partnerships and create jobs for U.S. citizens. He should give them the tools to do this.

U.S. citizens overseas have been asking for RBT tax reform for nearly 50 years. It would be wrong and nonsensical to give tax relief to high-net-worth investors while 5 million hard working U.S. citizens continue to be burdened with double taxation, complex and costly filing requirements, lock-out from financial institutions, lock-out from investment opportunities and lock-out from job opportunities.

RBT legislation has already been well researched, and several iterations drafted. The first RBT bill, The Tax Fairness for Americans Abroad Act, was introduced by Congressman Holding in 2018. Then, in 2024 Congressman LaHood introduced the Residence based taxation for Americans Abroad Act, which is scheduled for re-introduction in this Congress. Both these legislative efforts drew heavily on ACA’s modeling for RBT which scored a revenue cost of minimal to zero impact on the U.S. Treasury.

Many Members of Congress on both sides of the aisle understand that RBT will level the playing field for U.S. businesses as they compete with others to penetrate and expand foreign markets for American products and services. President Trump is thinking about RBT for Gold Card visa holders. RBT also fulfills his campaign promise to end double taxation for U.S. citizens living overseas.

Everything is ready for RBT to succeed: Presidential support to end double taxation, ACA’s RBT modeling, ACA’s research, bi-partisan support in Congress, and previously introduced legislation. The machinery to get RBT enacted may arrive via a tax omnibus bill, a government funding bill or immigration legislation. ACA is there working on all these opportunities. Support ACA today to make RBT a reality. We are 24/7 in D.C., up in Congress and working with partners.

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