Should Pope Leo XIV Renounce His U.S. Citizenship?
A Papacy with Unprecedented Tax Complications
When Cardinal Robert Francis Prevost was elected Pope Leo XIV in May 2025, history was made in more ways than one. Not only did the College of Cardinals select a deeply respected theologian and former missionary, but for the first time in the nearly 2,000-year history of the papacy, the new pontiff held United States citizenship.
This distinction, while a point of pride for many American Catholics, introduces an extraordinary legal and financial entanglement: Pope Leo XIV is, under U.S. law, still subject to the Internal Revenue Code. That means the Vicar of Christ, Bishop of Rome, and sovereign of the Vatican City State may also be expected to file annual income tax returns with the IRS, disclose foreign bank accounts to the U.S. Treasury, and report gifts or distributions received from foreign individuals, trusts, or institutions.
Though the Vatican operates as an independent sovereign state and the Pope, in both religious and political terms, transcends national affiliations, U.S. law does not make exceptions for spiritual leadership or international stature. American citizenship carries with it a uniquely burdensome feature: worldwide taxation, irrespective of residence or role.
This blog explores the key tax issues facing Pope Leo XIV and evaluates whether, renouncing U.S. citizenship may be the most prudent course. It is a case study in the far-reaching scope of U.S. tax law and what happens when it intersects with one of the world’s most influential spiritual offices.
Foreign Financial Accounts: Reporting Obligations and Sovereignty Tensions
Among the most burdensome features of U.S. citizenship is the requirement to report foreign financial accounts. Under the Bank Secrecy Act, any U.S. person with a financial interest in, or even just signature authority over, foreign accounts exceeding $10,000 must file an FBAR (FinCEN Form 114). Noncompliance can result in penalties of up to $100,000 or 50% of the account balance for willful violations, and $10,000 per year for non-willful failures.
For Pope Leo XIV, this obligation presents a real problem. As sovereign of Vatican City and head of the Catholic Church, he is presumed to hold authority, direct or indirect, over accounts held at the Vatican Bank. These accounts fund Church operations globally, and the Pope, as institutional leader, could be deemed to have reportable control under U.S. law. That would make him personally responsible for annual FBAR filings disclosing Vatican-held accounts.
In addition, the Foreign Account Tax Compliance Act (FATCA) requires foreign financial institutions, including the Vatican Bank, which signed a FATCA agreement in 2015, to report U.S. account holders to the IRS. The Pope, as a U.S. citizen, could be flagged as such, triggering parallel Form 8938 reporting requirements on his U.S. tax return.
These legal obligations create a tension between U.S. tax enforcement and the sovereign status of the Holy See. If the Pope is legally compelled to disclose Vatican financial data to the U.S. Treasury, it could be viewed as an intrusion on papal autonomy. Even inadvertent reporting lapses could subject the Pope to substantial civil penalties—an untenable situation both diplomatically and ecclesiastically.
Ultimately, this highlights a broader issue: whether a sitting pope should remain legally accountable to any foreign government. For Pope Leo XIV, renouncing U.S. citizenship may be the only way to resolve that contradiction.
Gifts, Bequests, and Foreign Trusts: The Form 3520 Burden
Although the papacy does not come with a traditional salary, Pope Leo XIV inevitably receives valuable gifts and benefits as head of the Catholic Church. For most U.S. citizens, such gifts, especially from foreign sources, can trigger complex and punitive reporting obligations. Chief among them is IRS Form 3520, which must be filed by any U.S. person who receives more than $100,000 in gifts or bequests from a nonresident alien or foreign estate, or more than $18,567 from foreign corporations or partnerships in 2025. While the gifts themselves are not taxed, failure to file the form can result in penalties of up to 25% of the gift’s value.
This is more than a theoretical concern. The Pope routinely receives high-value items from dignitaries and institutions, some of which may be reportable. A prominent example includes Pope Francis’s 2017 receipt of a Lamborghini Huracán, which was auctioned for charity. Had Pope Leo XIV received such a gift while retaining U.S. citizenship, it would likely fall under Form 3520 reporting rules.
Further complicating matters are the Vatican’s charitable foundations and endowments, many of which may be considered foreign trusts under U.S. law. Under IRC §6048, U.S. persons who create, transfer to, receive distributions from, or are treated as owners of foreign trusts must file Form 3520. Penalties can reach 35% of the value involved, with an additional requirement that the trust file Form 3520-A. Noncompliance, whether by oversight or misunderstanding, can carry heavy consequences.
For a religious leader tasked with spiritual guidance, this level of tax compliance is a significant burden. Pope Leo’s continued U.S. citizenship risks turning routine acts of ecclesiastical stewardship into potential IRS reporting events—making the case for renunciation even more compelling.
The Expatriation Option: Exit Tax and Covered Expatriate Rules
For Pope Leo XIV, the most effective way to eliminate the far-reaching tax obligations of U.S. citizenship is to formally renounce it. Under Internal Revenue Code Sections 877 and 877A, expatriating citizens may face an “exit tax” if they meet certain thresholds, classifying them as “covered expatriates.” These thresholds include: (1) a net worth of $2 million or more, (2) an average annual U.S. income tax liability exceeding $190,000 (adjusted for inflation), or (3) failure to certify five years of tax compliance on IRS Form 8854.
It is likely that Pope Leo would meet at least one of these criteria. As a sovereign head of state and former cardinal, his position alone could suggest sufficient wealth or financial responsibility to meet the net worth or compliance test. Even if he does not hold substantial assets personally due to vows of poverty, any reporting lapses could trigger covered expatriate status.
If classified as a covered expatriate, the Pope would be subject to a mark-to-market exit tax. This means the IRS treats him as having sold all global assets on the day before expatriation, taxing unrealized capital gains above a certain exclusion, $866,000 for 2024, adjusted annually. Special rules also apply to retirement plans, deferred compensation, and trust interests.
While this exit tax can be costly, it is a one-time burden, potentially far less disruptive than the indefinite compliance with FBAR, FATCA, and Form 3520 obligations. More importantly, renouncing U.S. citizenship would eliminate any claim by the IRS on the papacy’s financial affairs and reinforce the Vatican’s sovereign independence.
In practical and symbolic terms, expatriation may be the clearest path forward. It severs legal ties to U.S. jurisdiction and removes the conflict between a global spiritual office and a national tax regime.
Symbolic Considerations: Papal Independence and National Allegiance
Beyond the technical burdens of U.S. tax law, Pope Leo XIV’s American citizenship raises more profound questions, ones rooted in theology, history, and diplomacy. The Pope is not merely a prominent religious figure; he is the Bishop of Rome, leader of the universal Church, and sovereign of an independent state. His authority stems from apostolic succession and ecclesial tradition, not national identity. In that light, maintaining citizenship in a secular nation, even a democratic ally, introduces symbolic tensions that extend far beyond the realm of compliance.
At the heart of the issue is a question of perceived allegiance. Can the Pope, who is called to transcend political affiliations and speak for all Catholics, credibly retain legal citizenship in a powerful, globally influential country like the United States? While citizenship may not affect his spiritual office in substance, it inevitably colors perception, particularly in a geopolitical environment where American influence is both dominant and, in some quarters, distrusted.
The Vatican has a long history of guarding its autonomy. After the Papal States were annexed in 1870, successive popes rejected recognition of the Italian state and remained confined within Vatican walls for nearly six decades. That self-imposed isolation was more than symbolic; it underscored the papacy’s refusal to submit to secular authority. Pope Leo XIV’s U.S. citizenship, even if functionally inert, could be seen as inconsistent with this deeply ingrained posture of independence.
Practical hypotheticals, such as whether a pope could vote in U.S. elections or be called for jury duty, may never come to pass. But the very fact that such obligations could exist illustrates the awkwardness of the arrangement. Citizenship carries legal obligations. Obligations imply jurisdiction. And jurisdiction, for a sovereign religious leader, is not easily shared.
Renouncing U.S. citizenship would not be an act of disloyalty. It would be a reaffirmation that the papacy belongs to no one nation. Pope Leo XIV is not America’s pope—he is the pope who happens to be from America. That distinction, though subtle, is essential. In an increasingly polarized world, the credibility of the Holy See depends on a visibly unencumbered moral authority. Relinquishing American citizenship would strengthen that integrity and ensure that the spiritual leadership of the Catholic Church remains above, and apart from, worldly entanglements.
A Thoughtful and Necessary Decision
Pope Leo XIV’s American citizenship presents a singular challenge with both legal and symbolic consequences. While many Catholics take pride in his U.S. roots, the obligations tied to American citizenship are far from ceremonial. As a U.S. citizen, the Pope is subject to a demanding tax regime that includes reporting foreign income, disclosing Vatican bank accounts, and filing detailed forms for gifts and trust interests.
These requirements, FBAR, FATCA, Form 3520, and more, carry steep penalties for even minor oversights. They also raise an uncomfortable prospect: the reach of U.S. tax law extending into the internal affairs of the Holy See. For the pope, whose role is spiritual and global, this entanglement is both impractical and inappropriate.
More importantly, U.S. citizenship could compromise the perception of papal neutrality. The pope must be seen as belonging to the entire Church, not to any one nation. Renunciation would resolve these tensions, legally, diplomatically, and symbolically.
Again, this is not a rejection of the United States, but an affirmation of the papacy’s independence. For Pope Leo XIV, renouncing U.S. citizenship may be a necessary act of leadership, one that preserves the integrity of both his spiritual office and international law.
