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Multiple citizenship is a status in which a person is concurrently regarded as a citizen under the laws of more than one state. Multiple citizenships exist because different countries use different, and not necessarily mutually exclusive, citizenship requirements. Colloquial speech refers to people "holding" multiple citizenship but technically each nation makes a claim that this person be considered its national. For this reason, it is possible for a person to be a citizen of one or more countries, or even no country.
Individual countries follow their own rationales in establishing their criteria for citizenship. Each country has different requirements for citizenship, as well as different policies regarding dual citizenship. These laws sometimes leave gaps where the acquisition of other citizenships does not render the original citizenship invalid, creating a possible situation for an individual to hold two or more nationalities. Here are common reasons to bestow citizenship:
Once citizenship is bestowed, the bestowing country may or may not consider a voluntary renunciation of that citizenship to be valid. In the case of naturalization, some countries require applicants for naturalization to renounce their former citizenship. However, this renunciation may not be recognized by the bestowing country. Technically, the person in question may still possess both citizenships.
For example, United States Chief Justice John Rutledge ruled "a man may, at the same time, enjoy the rights of citizenship under two governments," but the US requires applicants for naturalization to renounce all prior allegiance to any other nation or sovereignty as part of the naturalization ceremony. In the case of a British citizen, however, the UK honors renunciation of citizenship only if done with competent UK authorities. Consequently, British citizens naturalized in the US remain British citizens in the eyes of the British government even after they renounce British allegiance to the satisfaction of U.S. authorities.
The Republic of Ireland frames its citizenship laws as relating to "the island of Ireland", thereby extending them to Northern Ireland, which is part of the United Kingdom. Therefore, anyone born in Northern Ireland who meets the requirements for being an Irish citizen through birth on the island of Ireland (or a child born outside of Ireland but with a qualifying parent) may exercise an entitlement to Irish citizenship by acting in such a way that only an Irish citizen is entitled to do (such as applying for an Irish passport). Conversely, that such a person has not acted in this way does not necessarily mean that they are not entitled to be an Irish citizen. See Irish nationality law and British nationality law. People born in Northern Ireland are British citizens on the same basis as people born elsewhere in the United Kingdom. People born in Northern Ireland may choose to hold a British passport, an Irish passport, or both.
Some countries consider multiple citizenship undesirable and take measures to prevent it. This may take the following forms:
In popular discourse, reference to countries that "recognize" multiple citizenship sometimes refer only to the lack of any specific statute forbidding multiple citizenship (leaving aside the difficulties of enforcing such statutes).
Some countries have more complex rules on dual and multiple citizenship. For example, Germany and Austria usually do not allow dual citizenship except for persons who obtain more than one citizenship at the time of birth Germans and Austrians can apply for a permit to keep their citizenship (Beibehaltungsgenehmigung) before taking a second one (for example, both Austria and the U.S. consider Arnold Schwarzenegger a citizen). In general however, any Austrian who takes up a second citizenship will automatically lose their Austrian citizenship. Spain has dual citizenship treaties with Bolivia, Chile, Ecuador, Colombia, Costa Rica, Guatemala, Nicaragua, Paraguay, Peru, the Dominican Republic, Argentina, and Honduras, and Spaniards residing in these countries do not lose their rights as Spaniards if they adopt that nationality. For all other countries, Spanish citizenship is revoked when the person becomes a citizen of that country.
The Constitution of India does not permit dual citizenship or dual nationality, except for minors where the second nationality was involuntarily acquired. Indian authorities interpreted this to mean a person cannot have another country's passport while simultaneously holding an Indian one, even the for a child claimed by another country as its citizen, who may be required by the laws of this country to use the corresponding passports for foreign travel (such as a child born in the United States to Indian parents). Indian courts have given the executive branch wide discretion over this matter.
In 2005, India amended the 1955 Citizenship Act to introduce a form of overseas citizenship, which stops just short of full dual citizenship and is in all aspects, like Permanent Residency. The Overseas Citizenship of India is not a full citizenship of India and so is exempt from the rule forbidding dual citizenship. However, bearers may not vote, run for office, join the army, or take up government posts. Moreover, people who have acquired citizenship in Pakistan or Bangladesh are not eligible for Overseas Citizenship.
Some countries consider multiple citizenship desirable as it increases opportunities for their citizens to compete globally, and/or have taken active steps towards permitting multiple citizenship in recent years (such as Switzerland since 1 January 1992 and Australia since 4 April 2002).
The rise in tension between mainstream and migrant communities is cited as evidence of the need to maintain a strong national identity and culture. They assert that the fact that a second citizenship can be obtained without giving anything up (such as the loss of public benefits, welfare, healthcare, retirement funds, and job opportunities in the country of origin in exchange for citizenship in a new country) both trivializes what it means to be a citizen and nullifies the consequential, transformational, and psychological change that occurs in an individual when they go through the naturalization process.
In effect, this approach argues, the self-centered taking of an additional citizenship contradicts what it means to be a citizen in that it becomes a convenient and painless means of attaining improved economic opportunity without any real consequences and can just as easily be discarded when it is no longer beneficial. Proponents argue that dual citizenship can actually encourage political activity providing an avenue for immigrants who are unwilling to forsake their country of origin either out of loyalty or due to a feeling of separation from the mainstream society because of language, culture, religion, or ethnicity.
A 2007 academic study concluded that dual citizens had a negative effect on the assimilation and political connectedness of first generation Latino immigrants to the United States:
The study also noted that although dual nationality is likely to disconnect immigrants from the American political system and impede assimilation, the initial signs suggest that these effects seem to be limited almost exclusively to the first generation (although it is mentioned that a full assessment of dual nationality beyond the first generation is not possible with present data).
Concern over the effect of multiple citizenship on national cohesiveness is generally more acute in the United States. The reason for this is twofold:
The degree of angst over the effects of dual citizenship seemingly corresponds to a country's model for managing immigration and ethnic diversity:
||The examples and perspective in this section deal primarily with the United States and do not represent a worldwide view of the subject. Please improve this article and discuss the issue on the talk page. (June 2009)|
People with multiple citizenship may be viewed as having dual loyalty, having the potential to act contrary to a government's interests, and this may lead to difficulties in acquiring government employment where security clearance may be required.
In the United States, dual citizenship is associated with two categories of security concerns: foreign influence and foreign preference. Contrary to common misconceptions, dual citizenship in itself is not the major problem in obtaining or retaining security clearance in the United States. As a matter of fact, if a security clearance applicant's dual citizenship is "based solely on parents' citizenship or birth in a foreign country", that can be a mitigating condition. However, taking advantage of the entitlements of a non-US citizenship can cause problems. For example, possession and/or use of a foreign passport is a condition disqualifying one from security clearance and "is not mitigated by reasons of personal convenience, safety, requirements of foreign law, or the identity of the foreign country" as is explicitly clarified in a Department of Defense policy memorandum which defines a guideline requiring that "any clearance be denied or revoked unless the applicant surrenders the foreign passport or obtains official permission for its use from the appropriate agency of the United States Government".
This guideline has been followed in administrative rulings by the United States Department of Defense (DoD) Defense Office of Hearings and Appeals (DOHA) office of Industrial Security Clearance Review (ISCR), which decides cases involving security clearances for Contractor personnel doing classified work for all DoD components. In one such case, an administrative judge ruled that it is not clearly consistent with US national interest to grant a request for a security clearance to an applicant who was a dual national of the US and Ireland, despite the fact that it has with good relations with the US.
In Israel, certain military units, including most recently the Israeli Navy's submarine fleet, as well as posts requiring high security clearances, require candidates to renounce any other citizenship before joining, though number of units making such demands has declined. In many combat units, candidates are required to declare but not renounce any foreign citizenship.
This perception of dual loyalty can apply even when the job in question does not require security clearance. In the United States, dual citizenship is not very common among politicians or government employees; however, it does occur. For example, Arnold Schwarzenegger retained his Austrian citizenship during his service as a Governor of California. In 1999, the U.S. Attorney General's office issued an official opinion that a statutory provision that required the Justice Department not to employ a non-"citizen of the United States" did not bar it from employing dual citizens.
In 2006, Boris Johnson (at the time a Member of the British Parliament and afterward Mayor of London) renounced the US citizenship he had acquired by being born in New York. He declared: "After 42 happy years I am getting a divorce from America. It is not just that I no longer want an American passport. In fact, what I want is the right not to have an American passport." His renunciation was prompted by US laws that require a US citizen entering the United States to use a US passport, rather than any other passport.
A small controversy arose in 2005 when Michaëlle Jean was appointed the Governor General of Canada (official representative of the Queen). Although Jean no longer holds citizenship in her native Haiti, her marriage to French-born filmmaker Jean-Daniel Lafond allowed her to obtain French citizenship several years before her appointment. Article 23-8 of the French civil code allows the French government to withdraw the French nationality from French citizens holding government or military positions in other countries and Jean's appointment made her both de facto head of state and commander-in-chief of the Canadian forces. The French embassy released a statement that this law would not be enforced because the Governor General is essentially a ceremonial figurehead. Nevertheless, Jean renounced her French citizenship two days before taking up office to end the controversy about it.
However, former Canadian Prime Minister John Turner was born in the United Kingdom and still retains his dual citizenship. Stéphane Dion, former head of the Liberal Party of Canada and the previous leader of the official opposition, holds dual citizenship with France as a result of his mother's nationality; Dion nonetheless indicated a willingness to renounce French citizenship if a significant number of Canadians viewed it negatively.
The Constitution of Australia, in Section 44(i), explicitly forbids people who hold foreign citizenship from sitting in the parliament of Australia. A court case (see Sue v Hill) determined that the UK is a foreign power for purposes of this section of the constitution, despite Australia holding a common nationality with it at the time that the Constitution was written, and that Senator-elect Heather Hill had not been duly elected to the national parliament because at the time of her election she was a subject or citizen of a foreign power. (This restriction does not apply to members of the state parliaments, where regulations vary by state.)
In New Zealand, controversy arose in 2003 when Labour MP Harry Duynhoven applied to renew his citizenship of the Netherlands. Duynhoven, the New Zealand-born son of a Dutch-born father, had possessed dual citizenship from birth but had temporarily lost his Dutch citizenship due to a 1995 change in Dutch law regarding non-residents. While New Zealand's Electoral Act allowed candidates with dual citizenship to be elected as MPs, Section 55 of the Act stated that an MP who applied for citizenship of a foreign power after taking office would forfeit his/her seat. This was regarded by many as a technicality, however; and Duynhoven, with his large electoral majority, was almost certain to re-enter Parliament in the event of a by-election. As such, the Labour Government retrospectively amended the Act, thus enabling Duynhoven to retain his seat. The amendment, nicknamed "Harry's Law", was passed by a majority of 61 votes to 56. The revised Act allows exceptions to Section 55 on the grounds of an MP's country/place of birth, descent, or renewing a foreign passport issued before the MP took office.
Both the current[update] Estonian president Toomas Hendrik Ilves and the former Lithuanian president Valdas Adamkus had been naturalized US citizens prior to assuming their offices. Both have renounced their U.S. citizenships: Ilves in 1993 and Adamkus in 1998. This was necessary because neither individual's new country permits retention of a former citizenship. Adamkus was a high-ranking official in the Environmental Protection Agency, a federal government department, during his time in the United States.
In some cases, multiple citizenship can create additional tax liability. Most countries that impose tax normally base tax liability on source and/or residency. Very few countries base tax liability on citizenship, the major exception being the United States which uses citizenship as well as residency and source as a basis for determining tax liability.
Only two countries base taxation on citizenship: the United States and Eritrea.A few countries, such as the Philippines considers citizenship to a limited extent. Only U.S. expatriates are subject to tax on all of their worldwide income, although U.S. law provides measures to reduce or eliminate double taxation issues for some expatriates. It has been reported that some U.S. expatriates have renounced U.S. citizenship in order to avoid this tax burden.
A person with multiple citizenship may have a tax liability to his country of residence and also to one or more of his countries of citizenship; or worse, if unaware that one of his citizenships created a tax liability, that country may consider the person to be a tax evader. Many countries and territories have contracted tax treaties or agreements for avoiding double taxation. Still, there are cases in which a person with multiple citizenship will owe tax solely on the basis of holding one of those citizenships.
For example, consider a person who holds both Australian and United States citizenship, lives and works in Australia. He would be subject to Australian taxation, because Australia taxes its residents, and he would be subject to US taxation because he holds US citizenship. In general, he would be allowed to subtract the Australian income tax he paid from the US tax that would be due. Plus, the US will allow some parts of foreign income to be exempt from taxation; for instance, in 2006 the foreign earned income exclusion allowed up to US$82,400 of foreign salaried income to be exempt from income tax. This exemption, plus the credit for foreign taxes paid mentioned above, often results in no US taxes being owed, although a US tax return would still have to be filed. In instances where the Australian tax was less than the US tax, and if there was income that could not be exempted from US tax, the US would expect any tax due to be paid.
The United States Internal Revenue Service has excluded some regulations such as Alternative Minimum Tax (AMT) from tax treaties that protect double taxation. In its current format even if US citizens are paying income taxes at a rate of 56%, far above the maximum US marginal tax rate, the citizen can be subject to US taxes because the calculation of the Alternative Minimum Tax does not allow full deduction for taxes paid to a foreign country. Other regulations such as the post date of foreign mailed tax returns are not recognized and can result in penalties for late filing if they arrive at the IRS later than the filing date.
However, the filing date for overseas citizens has a two month automatic extension to 15th of June.
"If you are a U.S. citizen or resident alien residing overseas, or are in the military on duty outside the U.S., on the regular due date of your return, you are allowed an automatic 2-month extension to file your return and pay any amount due without requesting an extension. For a calendar year return, the automatic 2-month extension is to June 15.
If you are unable to file your return by the automatic 2-month extension date, you can request an additional extension to October 15 by filing Form 4868 before the automatic 2-month extension date. However, any tax due payments made after June 15 will be subject to both interest charges and failure to pay penalties." (IRS, 2012)
Many countries, even those that permit multiple citizenship, do not explicitly recognise multiple citizenship under their laws: individuals are treated either as citizens of that country or not, and their citizenship with respect to other countries is considered to have no bearing. This can mean (in Iran, Mexico, many Arab countries, and former Soviet republics) that consular officials abroad may not have access to their citizens if they also hold local citizenship. Some countries provide access for consular officials as a matter of courtesy, but do not accept any obligation to do so under international consular agreements. The right of countries to act in this fashion is protected via the Master Nationality Rule.
Multiple citizens who travel to a country that claims them as a citizen may be required to enter or leave the country on that country's passport. For example, a United States Department of State web page on dual nationality contains the information that most U.S. citizens, including dual nationals, must use a U.S. passport to enter and leave the United States. Also, terms of the South African Citizenship Act, it is an offence for someone aged at least 18 with South African citizenship and another citizenship to enter or depart the Republic of South Africa by using of the passport of another country. They may also be required to fulfill requirements ordinarily required of its resident citizens, including compulsory military service or exit permits.
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