April 28, 2026 • 25 minute read

Residency-based taxation for Americans overseas: A review of the LaHood Bill

By Ross McGill

Ross is the founder and chairman of TConsult. He has spent over 26 years working in the withholding tax landscape with companies developing tax reclaim software and operating outsource tax reclamation services.

Ross not only sees the big picture but is also incredibly detail oriented. He can make even the most complex issues simple to understand. He has authored 10 books (including two second editions) on various aspects of tax, technology, and regulation in financial services, making him one of the leading authorities in the world of tax.

Picture of a US passport on a table surrounded by a cup of coffee, a pencil and a plant

A review of the LaHood Bill

For decades, the United States has stood apart in taxing its citizens based on nationality rather than residence. This is a model that has created persistent friction for Americans living overseas and the financial institutions that serve them. The proposed LaHood Bill signals a potentially significant shift in that paradigm, reopening the question of whether citizenship-based taxation is still fit for a globally mobile world.

In this piece, Ross McGill examines the LaHood Bill not just as a policy proposal, but as a structural inflection point. A move toward residency-based taxation could ease long-standing pain points such as double taxation and financial exclusion. But it may also introduce a more complex and less predictable reporting environment – one that challenges the coherence of FATCA, interacts unevenly with CRS, and forces financial institutions to rethink long-established operating models.

What emerges is a deeper question: does the LaHood Bill simplify the system, or merely redistribute its complexity? In this article, Ross argues, the answer will shape not only the future of U.S. tax policy, but the broader architecture of cross-border reporting and compliance.

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