The IRS is contemplating a significant alteration to Form 1040, which may require taxpayers to self-identify as non-U.S. citizens or dual citizens, marking the first such distinction in the form’s history.
The Internal Revenue Service (IRS) is currently evaluating a proposal to include a citizenship-status question on the 2024 version of Form 1040. This consideration comes amid ongoing discussions within the agency, as reported by Reuters, citing three sources familiar with the deliberations. The proposed change would introduce a checkbox for filers to indicate whether they are non-U.S. citizens or hold dual citizenship.
The IRS’s parent agency, the Treasury Department, has not commented on the issue, and no formal rulemaking or timeline for implementation has been announced. This potential modification could have wide-ranging implications for American taxpayers, especially those with dual nationality.
Details of the Proposal
Two draft versions of Form 1040 are under review by IRS officials. While both drafts feature standard legislative updates, only the second draft introduces a new line: “Check this box if you are a non-U.S. citizen or have dual citizenship.” Historically, Form 1040 has not differentiated between citizens and non-citizens in its filing structure. If adopted, this checkbox would represent a significant shift in the IRS’s approach to taxpayer identification.
In addition to the proposed citizenship question, the IRS is exploring the possibility of modifying Individual Taxpayer Identification Number (ITIN) codes to flag a taxpayer’s immigration status. ITINs, which are nine-digit numbers, are assigned to non-citizens for tax purposes in lieu of Social Security numbers.
Impact on Dual Citizens
The implications of this proposal extend beyond undocumented immigrants, who are required to file U.S. taxes and whose compliance can influence their legal status. Approximately five million Americans hold citizenship in at least one other country. For these individuals, as well as clients of the investment migration market, the checkbox would create a formal record that links their tax filings to their dual nationality under penalty of perjury.
The United States is one of the few countries that employs a citizenship-based taxation system, requiring Americans to report and pay taxes on their worldwide income, regardless of their residency. This policy is shared only with Eritrea. Since the implementation of the Foreign Account Tax Compliance Act (FATCA) in 2010, foreign financial institutions have been mandated to report accounts held by U.S. persons, further complicating the financial landscape for dual citizens and expatriates.
Adam Juchniewicz, founder and CEO of Bitcitizen, commented on the potential implications of this proposal: “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.”
Broader Context
The proposed addition to Form 1040 is not an isolated initiative but rather part of a broader trend observed over the past several years. The Trump administration initiated efforts to integrate citizenship verification into various federal systems, including financial institutions.
In April, the White House began drafting an executive order that would require U.S. banks to collect proof of citizenship from account holders, diverging from existing Know Your Customer (KYC) standards. The draft order specified that conventional identification documents, such as REAL ID credentials, would not suffice in establishing citizenship.
Moreover, in December 2025, Senator Bernie Moreno introduced the Exclusive Citizenship Act, which sought to eliminate dual citizenship entirely, compelling Americans with foreign nationality to choose one passport within a year. Despite its introduction, GovTrack assessed the bill’s chances of enactment at a mere 3%.
Data Sharing and Compliance Concerns
In 2025, the Treasury Department and the Department of Homeland Security (DHS) sought to share confidential taxpayer data with Immigration and Customs Enforcement (ICE) for deportation purposes. This initiative faced legal challenges, and a federal judge blocked the disclosures after the Center for Taxpayer Rights filed suit. The IRS later acknowledged in court that it had mistakenly shared data on over 42,000 taxpayers with DHS, raising significant privacy concerns.
A report from the Yale Budget Lab estimated that declining tax compliance among immigrant communities—driven by anxiety over tax filings potentially exposing them to enforcement actions—could result in a loss of $313 billion in federal revenue over the next decade. The report highlighted that undocumented workers contributed approximately $66 billion in federal taxes in fiscal year 2023, with two-thirds of that amount coming from payroll taxes.
Next Steps
The IRS has yet to reach a final decision regarding the inclusion of the citizenship checkbox on Form 1040. Since the proposal does not require congressional approval, the agency retains administrative authority over the design of tax forms. Should the checkbox be implemented, Americans who have obtained second citizenships through various means would need to consider its implications, as failing to disclose this information could lead to perjury charges.
