On 4 May 2026 Tax Notes published an article by SEAT co-founder Laura Snyder.
The article is entitled “Taxation Affects 14th Amendment Citizenship: A Critical Lesson.”
The article can be accessed outside a paywall via this link.
The article: (1) examines how citizenship-based taxation violates 14th Amendment citizenship, and (2) explains the danger not just for overseas Americans but for all in delegating matters of constitutional rights to the Joint Committee on Taxation (JCT).
For those born or naturalized in the United States, citizenship exists independently of any governmental authority. Our citizenship belongs to the individual, and only to the individual. It does not belong to anyone else. No governmental body – nor anyone else – has the right to affect our citizenship in any manner.
Words aside, the actions of overseas Americans demonstrate a clear rejection of this fact about our citizenship. We do not assert our citizenship rights. We accept as legitimate the principle of the taxation of our citizenship. To the extent we raise any questions about it, our questioning is limited to the manner of the taxation.
To make matters worse, we accept as legitimate Congress’s delegation to the JCT of the power to determine our citizenship rights. We act as if it’s perfectly normal for the JCT to get to decide the conditions under which we can be allowed to remain U.S. citizens. We act as if it’s perfectly normal for our citizenship to be dependent upon the JCT’s “score.”
We have accepted the sacrifice of our constitutional citizenship on the altar of revenue neutrality. And we are complicit in the act of this sacrifice.
Unless and until we find the courage to take back our citizenship from the JCT, we deserve what we will get. Which is nothing.
Will we find the courage during my lifetime? I’ve seen no reason for optimism. As a group, overseas Americans suffer from an appalling and shameful lack of courage.
Again, the article can be accessed via this link.
