A provision in the highway bill, which is currently being reconciled by the conference committee, will allow the Department of State to nullify passports of those owing $50,000 or more in federal taxes, interest and penalties.

Estimates by the Joint Committee on Taxation project the law will raise $398 million over the next 10 years, The Wall Street Journal reports. Those who are paying down their delinquent taxes to the Internal Revenue Service in a payment plan or legally contesting a tax case would not be subject to the rule.

The provision does allow for exceptions to be made in the case of a “humanitarian” emergency.

Critics of the measure say it discriminates against Americans living abroad. In a letter written to Congress in early-November, American Citizens Abroad, a non-profit advocacy group, said no action should be taken until hearings have been held to discuss the implications that may result in its implementation.

The law is expected to take effect January 2016.

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