Advocacy Submissions
AARO has written repeatedly to Congressional representatives, administration officials, government agencies and others advocating for your rights.
In our submissions we provide them with important information, ask for their support of certain legislation and advocate on overseas Americans’ issues in a wide range of areas, including Banking, FATCA/FBAR, Taxation, Citizenship and Social Security/Medicare. Below is a compilation of the more recent submissions, those written from January 2020 to the present.
Click on the links below to see the submissions in each area.
Banking
Submission to the office of Representative Barr (R. KY), co-sponsor of "de-banking" legislation (H.R. 987 and H.R. 2702), on October 24, 2025, suggesting how the President’s Executive Order “Guaranteeing Fair Banking for All Americans” could be broadened to eliminate “de-banking” of Americans living outside the United States and providing specific minor drafting amendments.
Barr/Fair Access to Banking/October 24, 2025
Submission to the office of Senator Cramer (R. ND), co-sponsor of banking legislation (S. 401), on October 24, 2025, suggesting how the President’s Executive Order “Guaranteeing Fair Banking for All Americans” could be broadened to eliminate “de-banking” of Americans living outside the United States and providing specific minor drafting amendments.Cramer/Fair Access to Banking/October 24, 2025
Document sent as an attachment to the submissions to the offices of Senator Cramer (R. ND) and Representative Barr (R. KY), on October 24, 2025, indicating the minor drafting amendments needed to broaden the President’s Executive Order “Guaranteeing Fair Banking for All Americans” to eliminate “de-banking” of Americans living outside the United States.Cramer-Barr/Banking Executive Order/October 24, 2025
Submission to the Financial Crimes Enforcement Network (FinCEN) on September 3, 2024, responding to an invitation for comment on a proposed rule on anti-money laundering and countering the financing of terrorism, stating that the existing regulatory framework results in overseas Americans facing high costs and restrictions on access to, or exclusion from, the U.S. financial system and that a fundamental review of the whole framework is needed.FinCEN/AML/September 3, 2024
Letter to the Pensions and Tax Policy Director of the Senate Committee on Health, Education, Labor and Pensions (HELP) on September 6, 2023, outlining priority changes that AARO would like to see added to a retirement or tax package to address the exclusion of overseas Americans from the financial system and their lack of access to savings vehicles and retirement plans.Senate HELP Director/Retirement Legislation/Sept. 6, 2023
Letter to the Americans Abroad Caucus on November 29, 2022, asking the Caucus to address the exclusion of overseas Americans from the financial system and their lack of access to savings vehicles and retirement plans via the pending retirement legislation Secure Act 2.0 (H.R. 2954) and Earn Act (S. 4808). AARO also directed the Caucus to an article on the topic authored by AARO.House Americans Abroad Caucus/Retirement Legislation/Nov. 29, 2022
Letter to the House Ways & Means Committee on November 29, 2022, asking the Committee to address the exclusion of overseas Americans from the financial system and their lack of access to savings vehicles and retirement plans via the pending retirement legislation Secure Act 2.0 (H.R. 2954) and Earn Act (S. 4808). AARO also directed the Committee to an article on the topic authored by AARO.House Ways & Means/Retirement Legislation/Nov. 29, 2022
Follow-up letter to the Senate Finance Committee on November 21, 2022, regarding the pending retirement legislation, reminding them of our June 30, 2022 letter to them and informing the Committee of an article on the topic authored by AARO.Senate Finance/Retirement Legislation/Nov. 21, 2022
Letter to the Chair and Ranking Member of the House Ways & Means Committee on November 21, 2022, regarding the pending retirement legislation Secure Act 2.0 (H.R. 2954) and EARN Act (S. 4808), requesting that, during the reconciliation of the House and Senate bills, provisions be added to reduce the financial exclusion of Americans abroad. AARO also informed them of an article on the topic authored by AARO.House Ways & Means Chair/Retirement Legislation/Nov. 21, 2022
Letter to the Senate Committee on Health, Education, Labor and Pensions (HELP) on July 15, 2022, regarding their pending retirement legislation Rise and Shine Act (S. 4353), urging them to make suitable modifications to it in order to reduce the financial exclusion that expats face in their retirement and investment accounts.Senate HELP/Retirement Legislation/July 15, 2022
Letter to the Senate Finance Committee on July 30, 2022, regarding the pending retirement legislation which passed the House and moved to the Senate, Secure Act 2.0 (H.R. 2954), urging them to make suitable modifications in reconciliation in order to reduce the financial exclusion that expats face in their retirement and investment accounts.Senate Finance/Retirement Legislation/June 30, 2022
Comment sent to the Financial Crimes Enforcement Network (FinCEN) on February 14, 2022, recommending ways to streamline, modernize and update the anti-money laundering and countering the financing of terrorism (AML/CFT) regime.FinCEN/AML CFT/Feb 14, 2022
Letter to the Acting Commissioner of the Bureau of the Fiscal Service at the Department of the Treasury on March 12, 2021, asking the Department to offer non-resident Americans pre-paid debit cards as an option for their distribution of the stimulus payments under the American Rescue Plan Act of 2021.Treasury Department/Stimulus Debit Cards/March 12, 2021
FATCA / FBAR
Amicus curiae brief filed by Jones Day on behalf of AARO with the Ninth Circuit Court of Appeals in United States v. Tuncay Saydam, a case challenging the constitutionality of large FBAR penalties. In the brief, AARO highlighted the reality that many ordinary Americans abroad are unaware of the FBAR filing requirement and can face devastating penalties despite no intent to violate the law.9th Cir. Court of Appeals/FBAR Amicus Brief/May 22, 2026
Submission to the Internal Revenue Service (IRS) on March 20, 2026, responding to an invitation for comment with respect to proposed updates to the IRS' Voluntary Disclosure Practice, requesting that the IRS provide greater transparency and clarity concerning the penalty structure, suggesting minimal to no penalties for delinquent or amended FBARs, and requesting drastic simplification and more awareness of reporting obligations.IRS/FBAR/March 20, 2026
Submission to the Office of Management and Budget on April 24, 2024, responding to an invitation for comment on the Department of Treasury’s proposal to renew FBAR information requirements, stating that the FBAR report has outlived any usefulness and proposing that, at a minimum, FATCA Form 8938 and FBAR be consolidated, along with interim alternatives.OMB/FBAR/April 24, 2024
Submission to the Financial Crimes Enforcement Network (FinCEN) on October 9, 2023, in response to an invitation for comment by FinCEN on renewal, without change, of existing information collection requirements on FBAR saying the FBAR report is “not necessary for the proper performance of the functions of the agency, nor does it have practical utility.”FinCEN/FBAR/Oct. 9, 2023
Letter to French President Emmanuel Macron on November 30, 2022, in connection with his impending trip to the United States to visit President Biden, asking President Macron to address with him the difficulties of FATCA compliance by Americans living in France.President Macron/FATCA/Nov. 30, 2022.EnglishPresident Macron/FATCA/Nov. 30, 2022.French
Submission to the Financial Crimes Enforcement Network (FinCEN) on January 19, 2021, in response to an invitation for comments by FinCEN on whether its FBAR activities fulfill the agency's purposes, saying the FBAR report is “unnecessary, even counterproductive.”
FinCEN/FBAR/Jan. 19, 2021
Taxation
Letter to President Trump on June 16, 2026, informing him that Americans abroad find themselves shackled with unreasonable bureaucratic and financial burdens due to double taxation, FATCA/FBAR reporting obligations and draconian penalties, and asking him to help introduce a sense of urgency to pass the Residence-Based Taxation for Americans Abroad Act (H.R. 10468 from the 118th Congress) when it is reintroduced.President Trump/RBT/June 16, 2026
Submission to Chairman Mike Crapo, Ranking Member Ron Wyden and the remainder of the U.S. Committee on Finance on March 31, 2025, commenting on the discussion draft of the Taxpayer Assistance and Service Act (TSA), which is intended to make adjustments to the laws governing Internal Revenue Service procedures and administration, expressing AARO's support for the TSA and providing additional proposals for consideration.Crapo-Wyden/Taxpayer Assistance and Service Act/March 31, 2025
Submission to the Internal Revenue Service on November 4, 2024, commenting on the IRS's proposed Paperwork Reduction Act submission to the Office of Management and Budget concerning the compliance burden relating to U.S. Income Tax Forms, expressing AARO's position that the IRS seriously understates the paperwork burden created by tax-related filing requirements in that relevant reports are not considered and taxpayer time is not realistically valued. Overall, a more fundamental review of the whole tax framework is needed.IRS/Income Tax Forms/November 4, 2024
Submission to the office of Senator John Fetterman (D. PA) on September 9, 2024, responding to a request to elaborate on H.R. 5432 – Tax Simplification for Americans Abroad Act (the "Beyer bill”), in which AARO noted that, although it would make important progress in the area of taxation of overseas Americans, it could be extended to the areas of retirement planning and retail saving activity in order to mitigate financial access problems.Fetterman/Beyer Bill/September 9, 2024
Submission to the office of Representative Jason Smith (R. MO) on August 1, 2024, asking that the Representative support Senator Warner's expected to be proposed bi-partisan bill aimed at reducing the administrative burden of certain IRS regulations and FBAR filings.J. Smith/PossibleTax Bill/August 1, 2024
Submission to the office of Representative Ron Estes (R. KS) on July 30, 2024, asking that the Representative support Senator Warner's expected to be proposed bi-partisan bill aimed at reducing the administrative burden of certain IRS regulations and FBAR filings.Estes/Possible Tax Bill/July 23, 2024
Submission to the office of Representative Kevin Hern (R. OK) on July 30, 2024, asking that the Representative support Senator Warner's expected to be proposed bi-partisan bill aimed at reducing the administrative burden of certain IRS regulations and FBAR filings.Hern/PossibleTax Bill/July 23, 2024
Submission to the office of Senator Mark Warner (D. VA) on July 23, 2024, supporting a bi-partisan bill expected to be proposed by the Senator, aimed at reducing the administrative burden of certain IRS regulations and FBAR filings, but also requesting that FBAR and FATCA filings be consolidated into a single filing based on FATCA, as has been proposed in the Tax Simplification for Americans Abroad Act (H.R.5432).Warner/Possible Tax Bill/July 23, 2024
Submission to the Internal Revenue Service on July 8, 2024, commenting on proposed IRS regulations on information reporting on transactions with foreign trusts and large foreign gifts, expressing AARO’s position that non-U.S. pensions and retirement plans should not be subject to reporting requirements as foreign trusts and, in general, that tax and financial reporting regimes designed to combat abusive offshore schemes used by U.S. residents should not be applied to savings vehicles and retirement plans organized outside the United States.IRS/Foreign Trusts/July 8, 2024
Submission to the House Ways and Means Committee on April 25, 2024, responding to an invitation to comment on the benefits of the 2017 Tax Cuts and Jobs Act (TCJA), expressing AARO’s perspective that the tax system needs simplification, the favored treatment of foreign individuals and corporations with respect to U.S.-source passive income should end, and that U.S. citizens living overseas should not be taxed on non-U.S. source income based on citizenship.House Ways & Means/TCJA/April 25, 2024
Amicus curiae brief jointly filed by AARO and Stop Extraterritorial American Taxation (SEAT) with the Supreme Court in relation to Charles G. Moore, et al. v. United States, concerning the retroactive imposition of transition taxes on the Moores for unrealized earnings on a 13% investment in an Indian company. The brief outlined the onerous and discriminatory burdens placed on Americans abroad by citizenship based taxation and the hardships that flow from it, such as the transition tax at issue in Moore.
Supreme Court/Moore Case Amicus Brief/Sept. 5, 2023
Submission to the House Ways and Means Committee on August 1, 2023, expressing concerns about the extra-territorial taxation of overseas Americans and the paradox created by the Committee’s objection to a proposed new framework on corporate taxation, and asking the Committee to hold hearings focused on the taxation of overseas U.S. citizens.House Ways & Means/CBT/August 1, 2023
Letter to the House Ways and Means Committee on June 27, 2022, by the RBT Coalition, of which AARO is a member, to request that the Committee hold a hearing on the taxation of Americans abroad and related tax and compliance issues and, more specifically, on three bills dealing with these subjects.House Ways & Means/RBT Coalition/June 27, 2022
Submission to the Senate Finance Committee on September 3, 2021, asking that proposed business tax legislation reverse the damage caused by the 2017 Tax Cuts and Jobs Act, which adversely affected small businesses operating overseas and, in particular, to eliminate the burden of the Global Intangible and Low Income (GILTI) Tax and the Transition Tax, as they affect small businesses outside the United States.Senate Finance/GILTI/Sept 3, 2021
Submission to the Senate Finance Committee on May 25, 2021, commenting on administration plans to reduce the “tax gap,” and urging the IRS to ensure that its rules targeting offshore evasion be subject to careful regulatory impact assessments and that unintended assaults on compliant, law-abiding, working class, middle class and retired Americans, as well as small businesses, be avoided.Senate Finance/Tax Gap/May 25, 2021
Submission to the Senate Finance Committee on May 11, 2021, informing the Committee of AARO’s 2020 survey results and urging Congress to support H.R. 2710, which would establish a Commission on Americans Living Abroad.Senate Finance/Survey and HR 2710/May 11, 2021
Submission to the Senate Finance Committee on April 7, 2021, urging the Committee, when Congress revisits the 2017 Tax Cuts and Jobs Act, to take into account the inadvertent damage caused by this Act to small business owners and overseas American workers and entrepreneurs, and to correct this damage.Senate Finance/Small Businesses/April 7, 2021
Letter to the Taxpayer First Act Office of the IRS on January 16, 2020, informing them of the barriers taxpayers face in getting IRS services, how the IRS' organizational structure can be modernized and how the IRS can improve its communications with taxpayers.IRS Taxpayer First/IRS Services/January 16, 2020
Citizenship
Letter to the Department of State Bureau of Consular Affairs on July 3, 2023, requesting the inclusion on their website of information relating to the various non-partisan groups – such as AARO – that provide support to U.S. citizens residing abroad.Department of State/AARO on Website/July 3, 2023
Letter to Secretary of State Antony Blinken on June 30, 2022, to express AARO’s desire to work with the State Department more closely on passport related matters.Secretary of State/Passport Matters/June 30, 2022
Submission to the Subcommittee on Immigration and Citizenship of the U.S. House Judiciary Committee on May 5, 2021, expressing support for the American Families United Act (H.R. 2920).House Judiciary Committee/American Families/May 5, 2021
Letter to the Office of Policy and Strategy in the U.S. Citizenship and Immigration Services, Department of Homeland Security on November 2, 2020, providing its comments on proposed rule changes concerning the Affidavit of Support which is filed in conjunction with a Petition for Alien Relative.U.S. Citizenship and Immigration Services/Affidavit of Support/ Nov. 2, 2020
Social Security / Medicare
Letter to Majority Leader Schumer on December 11, 2024, urging him to bring the House version of the Social Security Fairness Act of 2023 (H.R. 82) to a vote on the Senate floor.Schumer/WEP repeal/December 11, 2024
Three letters sent by AARO to each of Senators McConnell, Crapo and Wyden on December 11, 2024, asking them to urge Senator Schumer to bring the House version of the Social Security Fairness Act of 2023 (H.R. 82) to a vote on the Senate floor. Key Senators/WEP repeal/December 11, 2024
Five letters sent by AARO to each of Senators Schumer, McConnell, Crapo, Grassley and Wyden on November 21, 2024, urging them to prioritize the Social Security Fairness Act of 2023 (S. 597) and to bring it to a vote on the Senate floor.Key Senators/WEP repeal/November 21, 2024
Twenty-seven letters sent by AARO, one to each member of the Senate Finance Committee, on November 19, 2024, urging them to ensure that the Social Security Fairness Act of 2023 (S. 597), which proposes to repeal the Windfall Elimination Provision, reaches the Senate floor; asking them to urge Majority Leader Schumer to schedule a vote on S. 597; and asking them to vote in favor of S. 597.Senate Finance/WEP repeal/November 19, 2024
Letter by AARO to Majority Leader Chuck Schumer and Minority Leader Mitch McConnell on November 12, 2024, urging them to immediately schedule a vote in the Senate on the Social Security Fairness Act (S. 597), which proposes to repeal the Windfall Elimination Provision.Schumer-McConnell/WEP repeal/November 12, 2024
One hundred letters sent by AARO, one to each Senator, on November 07-11, 2024, urging them to vote in favor of the Social Security Fairness Act of 2023 (S. 597), which proposes to repeal the Windfall Elimination Provision.Bill co-sponsor/WEP repeal/November 07, 2024Bill non sponsor/WEP repeal/November 11, 2024
Submission to the House Ways and Means Committee on April 23, 2024, responding to an invitation to comment on the Windfall Elimination Provision (WEP) and Government Pension Offset, expressing AARO’s view that the WEP should be repealed and AARO's support for the bipartisan Social Security Fairness Act, H.R. 82 and S. 597, that would do so.House Ways & Means/WEP/April 23, 2024
Letter to the Secretary of the U.S. Department of Health and Human Services on April 20, 2022, in support of a reduction in the premium for Medicare Part B.Department of HHS/Medicare Part B/April 20, 2022
Voting
Comment to the U.S. Postal Service (USPS) on July 2, 2026, by AARO and other organizations in response to a request for comment by the USPS on its proposed amendments to the Domestic Mail Manual regarding the transmission of mail-in or absentee ballots for federal elections. In the comment AARO and the others stated that the proposed amendments were unlawful and that the USPS must withdraw them entirely.USPS/Mail in Ballots/July 2, 2026
Lawsuit entitled League of Women Voters of Massachusetts et al v. Trump et al, filed with the U.S. District Court for the District of Massachusetts by the Brennan Center for Justice, American Civil Liberties Union and other counsel on behalf of AARO, the U.S. Vote Foundation and a coalition of voting rights organizations, challenging President Trump’s March 31, 2026 Executive Order on mail-in voting. Among its mandates, the Executive Order permits and empowers the U.S. Postal Service to determine who is allowed to cast a ballot by mail, an unconstitutional violation of the separation of powers.
MA District Court/Voting Lawsuit/April 2, 2026
Letter to the offices of all 48 Republican Senators who co-sponsored the Safeguard American Voter Eligibility (SAVE America) Act (H.R. 7296 / S. 1383), on March 18, 2026, urging them to oppose the SAVE America Act.Key Republican Senators/SAVE America Act/March 18, 2026
Letter to the offices of all 52 Senators who had not yet co-sponsored the Safeguard American Voter Eligibility (SAVE America) Act (H.R. 7296 / S. 1383), on March 5, 2026, urging them to oppose the SAVE America Act.Key Senators/SAVE America Act/March 5, 2026
Amicus curiae brief filed by the Brennan Center for Justice and Covington & Burling LLP on behalf of AARO, the U.S. Vote Foundation and more than 60 organizations, retired defense officials, military leaders, and diplomats with the U.S. Supreme Court in relation to Watson v. Republican National Committee, urging the Court to uphold state “grace periods” that allow timely mailed ballots to be counted if received after Election Day. A total of 30 states, the District of Columbia, and three U.S. territories allow grace periods. A ruling against Mississippi’s bipartisan grace period law could eliminate these protections, putting overseas voters at risk.
U.S. Supreme Court/Voting Amicus Brief/January 9, 2026
Comment to the Election Assistance Commission on October 16, 2025, in response to a petition by the America First Legal Foundation requesting that the Commission require a passport or other citizenship document in the voter registration process. AARO urged the Commission to reject the request as it would disenfranchise overseas Americans.EAC/America First Petition/October 16, 2025
Letter to the offices of Representatives Barrett, Baumgartner, Harrigan, Breshhan, Hurd, Fong, Wied, Juan, Kean Jr. on April 3, 2025, urging them to oppose the Safeguard American Voter Eligibility (SAVE) Act (H.R. 22 / S. 128).Key Republicans/SAVE Act/April 3, 2025
Letter to the offices of Representatives Gluesenkamp Perez, Gonzalez, Golden, Davis and Cuellar on March 31, 2025, urging them to oppose the Safeguard American Voter Eligibility (SAVE) Act (H.R. 22 / S. 128).Key Democrats/SAVE Act/March 31, 2025
Joint letter to the House of Representatives on April 10, 2025, by AARO, the U.S. Vote Foundation, the Federation of American Women’s Clubs Overseas (FAWCO) and others, urging them to oppose the Safeguard American Voter Eligibility (SAVE) Act (H.R. 22 / S. 128).House of Reps/SAVE Act/April 10, 2025
Amicus curiae brief filed by the Brennan Center for Justice and Ballew Puryear on behalf of AARO, the U.S. Vote Foundation and impacted voters with the North Carolina Court of Appeals in relation to Jefferson Griffin v. North Carolina State Board of Elections and Allison Riggs, urging the court not to throw out lawfully cast ballots. AARO emphasized in the brief that judicial approval of Griffin's efforts would create chaos, and would open the floodgates to post-election litigation, destabilize the framework of laws and rules that enable election administration, and undermine faith and participation in the democratic process.NC Court of Appeals/Voting Amicus Brief/February 27, 2025
Amicus curiae brief filed by Brennan Center for Justice on behalf of AARO and others with the Pennsylvania Federal Court in relation to Hon. Guy Reschenthaler, et al., v. Secretary Al Schmidt, et al., advocating against the plaintiffs' request for segregation and verification of ballots received in Pennsylvania from overseas Americans. AARO emphasized in the brief that this requirement does not exist, that Plaintiffs’ request would impose unnecessary barriers to voting and disenfranchise American citizens living abroad, and that the right to vote is fundamental.
PA Federal Court/Voting Amicus Brief/Oct. 18, 2024
Letter to the Editor of the New York Times on October 20, 2023, expressing AARO's disappointment in a column by the Ethicist, in which he advised a Swedish/American that she had no “duty to vote” in the U.S. AARO also disagreed with his opinions that she was not invested politically in, nor had an ongoing interest in, the United States.NYT/Voting/October 20, 2023
General / Other Issues
Letter sent to Secretary of State, Marco Rubio, express AARO’s desire to work with the State Department on ongoing efforts to evacuate United States citizens from the Middle East.Rubio/ Evacuations/March 16, 2026
Letter sent to Assistant Secretary of State, Mora Namdar congratulating her appointment as Assistant Secretary of State for Consular Affairs. Namdar/ Introduction/March 14, 2026
Letter sent to each newly elected member of Congress on April 17, 2025, (78 in total) congratulating them for their recent election to the House or Senate and introducing AARO.New Congressmembers/Welcome/April 17, 2025
Letter sent to Congressmen Mike Bost and Mark Takano, Chairman and Ranking Member of the House Veterans Affairs Committee, on February 20, 2025, expressing AARO’s strong support for H.R. 439, the Veterans Foreign Medical Coverage Equality & Modernization Act of 2025.Bost-Takano/Veterans Foreign Medical Coverage/February 20, 2025
Submission sent to Representatives Don Beyer, Dina Titus, Darin LaHood, Maria Salazar and Gus Bilirakis, on February 20, 2025, asking them to co-sponsor H.R. 439, the Veterans Foreign Medical Coverage Equality & Modernization Act of 2025.Beyer-Titus-LaHood-Salazar-Bilirakis/Veterans Foreign Medical Coverage/February 20, 2025
Letter to Senator Cory Booker in support of the American Victims Overseas Act bill.Booker/ American Victims Overseas Act/December 16, 2024
Commentary to the Editor of The Hill on April 8, 2024, stating that legislation and regulations have unintended and harmful consequences for Americans living overseas, explaining that the overseas vote is diluted, and calling on Congress to grant the American global expatriate community a non-voting delegate in the House of Representatives.The Hill /Non-Voting Delegate/April 8, 2024
Dear 535 Campaign: 535 letters by AARO, along with SEAT (Stop Extraterritorial American Taxation), one to each member of Congress, on April 24, 2023, urging them to support the legal reforms necessary to allow overseas Americans to live ordinary lives.
Congress/Dear 535 Campaign/April 24, 2023
Letter to the editorial board at the Wall Street Journal on April 4, 2023, expressing its appreciation for an op-ed article calling attention to American expats’ taxation without representation and agreeing with the authors that overseas Americans should have a non-voting delegate in the House of Representatives.WSJ/Congressional Representation/April 4, 2023
Letter to Representative Don Beyer on February 17, 2022, expressing AARO's appreciation for his joining the Americans Abroad Caucus and thanking him for sponsoring the Tax Simplification Act, stating that the bill, although limited in scope, is a good first step towards alleviating the unfairness and harm caused by the CBT system.Beyer/Caucus and TSA/February 17, 2022
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