The Internal Revenue Service (IRS) is considering adding a citizenship-status question to next year’s Form 1040, according to a Reuters exclusive citing three people with knowledge of the deliberations.
One of two draft versions of the form under review includes a checkbox asking filers to declare whether they are non-US citizens or hold dual citizenship.
Treasury, the IRS’s parent agency, declined to comment. No formal rulemaking or timeline has been announced.
What the Proposal Contains
IRS officials have produced two competing drafts of next year’s Form 1040. Both include standard legislative updates. Only the second adds a single line: “Check this box if you are a non-U.S. citizen or have dual citizenship.”
Form 1040 has never distinguished between citizens and non-citizens in its core filing structure. If adopted, the checkbox would mark the first such distinction in the form’s history.
Separately, the IRS is exploring whether to differentiate individual taxpayer identification number (ITIN) codes to flag a filer’s immigration status, according to The New York Times. ITINs are nine-digit numbers that non-citizens use in place of Social Security numbers when filing federal taxes.
The Dual-Citizen Dimension
Coverage of the proposal has centered on its implications for undocumented immigrants, who are required to file US taxes and whose compliance has historically aided applications for legal status. Less discussed is the second half of the checkbox’s language: Dual citizenship.
An estimated five million Americans hold citizenship in at least one other country. For them, and for the globally mobile clients the investment migration market serves, the checkbox would create a formal, penalty-of-perjury record linking their tax filing to the fact of a second nationality.
The United States already operates one of the most extraterritorial tax regimes in the world. Citizenship-based taxation requires that Americans report and pay tax on worldwide income regardless of where they live, a policy shared only with Eritrea.
Since 2010, the Foreign Account Tax Compliance Act (FATCA) has compelled foreign financial institutions to report accounts held by US persons. A checkbox on Form 1040 would add a self-reporting layer to a system that already tracks American dual nationals through institutional channels.
Adam Juchniewicz, founder and CEO of Bitcitizen, characterized the proposal as part of a longer trajectory: “They are no longer asking where you earn. They are asking where else you belong. When a tax authority starts taking attendance on your other allegiances, it has stopped treating citizenship as a relationship and started treating it as a leash.”
A Pattern Across Federal Systems
The Form 1040 proposal is not an isolated initiative. It follows a series of moves by the Trump administration to embed citizenship verification across financial and administrative infrastructure.
In April, the White House began drafting an executive order that would require US banks to collect proof of citizenship from account holders, a departure from existing Know Your Customer (KYC) standards that rely on name, date of birth, and verified address. REAL ID credentials would not qualify under the draft order because they do not establish citizenship. Treasury Secretary Scott Bessent confirmed the draft was “in process.”
Before that, in December 2025, Senator Bernie Moreno introduced the Exclusive Citizenship Act, which would ban dual citizenship outright and force Americans holding foreign nationality to choose one passport within a year. GovTrack gave the bill a 3% chance of enactment.
The Data-Sharing Backdrop
Throughout 2025, Treasury and the Department of Homeland Security (DHS) worked to share confidential taxpayer data with Immigration and Customs Enforcement (ICE) for use in deportation operations. A federal judge blocked the disclosures in November after the Center for Taxpayer Rights filed suit. Washington appealed.
By February 2026, the IRS had conceded in court that it erroneously shared data on more than 42,000 taxpayers with DHS. Disclosing a taxpayer’s personal information outside of narrow legal exceptions carries penalties, including imprisonment.
The Yale Budget Lab estimated in April 2025 that declining tax compliance among immigrant communities, driven by fear that filing would expose them to enforcement, could cost the federal government US$313 billion in lost revenue over the following decade.
Estimates ranged from US$147 billion to US$479 billion, depending on how taxpayers and employers adjusted their behavior. Undocumented workers paid approximately US$66 billion in federal taxes in fiscal year 2023, roughly two-thirds through payroll levies.
What Comes Next
No final decision has been made on whether the citizenship checkbox will appear on next year’s Form 1040. The proposal does not require congressional approval; the IRS holds administrative authority over form design.
Americans who have acquired second citizenships through investment, descent, or naturalization abroad would face the checkbox alongside every other filer. Checking it, or not, would carry perjury consequences.
