Source: Washington Post
by Daniel A Witt
“Here’s a not uncommon situation confronted by tax attorneys and advisers: A U.S. citizen is suddenly, perhaps unexpectedly, elevated to a CEO position. And that CEO holds dual citizenship in a country with which the United States does not have a bilateral tax treaty. To complicate the situation, the company’s headquarters — or siège social, in international law — are in a third country with which the United States also does not have a bilateral tax treaty. I’m referring, if you haven’t already guessed, to Pope Leo XIV. He is an American citizen and a citizen of Peru. He is now also head of state of Vatican City, a sovereign nation. That’s a complicated tax posture under any circumstances. … absent some relief, His Holiness could spend next April 15 finishing a Form 1040. (One can only imagine the issues with valuing the Apostolic Palace as a fringe benefit or parsonage allowance.)” (07/10/25)