Let’s say I become a citizen of a country that doesn’t allow dual citizenship. During naturalization, new country B tells me I have to renounce citizenship from old country A.
Does that have any effects back in country A? How would country A know? Would country A even care if they found out?
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Renouncing citizenship is a formal process done at the consulate or embassy, so country A almost by definition has to know about it
Not like this:
I renounce citizenship!
I’m a dual citizen (Canada & USA, born Canadian). Part of naturalization in the US is the oath where you renounce citizenship from everywhere else. Thing is, most countries don’t care about that oath–Canada requires filing a special form and appearing before an official (IIRC) to renounce citizenship. I asked about the discrepancy–it turns out the US doesn’t actually care whether I’m a citizen elsewhere, largely because it’s difficult to figure it out and enforce it (this might have been the opinion of the immigration officer, not sure).
Hmmmm what? The USA absolutely allows dual citizenship.
U.S. law does not impede its citizens’ acquisition of foreign citizenship whether by birth, descent, naturalization or other form of acquisition, by imposing requirements of permission from U.S. courts or any governmental agency.
[…]
U.S. law does not require a U.S. citizen to choose between U.S. citizenship and another (foreign) nationality (or nationalities). A U.S. citizen may naturalize in a foreign state without any risk to their U.S. citizenship.
U.S. dual nationals owe allegiance to both the United States and the foreign country (or countries, if they are nationals of more than one). They are required to obey the laws of both countries, and either country has the right to enforce its laws.
Yes, I mentioned that the US doesn’t care about dual citizenship. But the naturalization oath might suggest otherwise:
“I hereby declare, on oath, that I absolutely and entirely renounce and abjure all allegiance and fidelity to any foreign prince, potentate, state, or sovereignty, of whom or which I have heretofore been a subject or citizen…”
There’s an apparent discrepancy between the oath and the US official stance on dual citizenship (per the links you posted).
Oaths in the United States aren’t worth the shit they’re smeared in. The oath of enlistment into the armed forces has some hogwash about defending the United States against all enemies “foreign and domestic.” Meanwhile gestures broadly around
The USA doesn’t care, because they don’t require you to renounce your citizenship, and neither does Canada. Some countries won’t let you obtain a 2nd citizenship, so you must renounce your original citizenship to get a new one.
Like others have said it depends on the countries, for example Argentina as the country A is impossible, because Argentinian nationality is irrevocable as per the constitution, so if you’re born in Argentina you can sign any paper county B asks, and they will get dutifully ignored by Argentina.
I’m working on some outdated memories, but IIRC:
Germany allows dual citizenship now, but used to not allow it in most cases. In those cases, if you applied for German citizenship, you had to express that you were willing to give up your old citizenship. Once you were granted citizenship, you had a certain amount of time (two years?) to show a certificate that you renounced your old citizenship. If you didn’t, your German citizenship would be revoked.
Actually, dual citizenship in Germany is only allowed for a few select non-EU countries. For everyone else: first you apply for citizenship. Then they say citizenship will be granted, under the condition that you provide proof of revoking your previous citizenship within 2 years. Then you revoke your previous citizenship and give the confirmation to the immigration department. They will process it (during those weeks you are practically stateless) and grant you citizenship on this basis. Source: did this three years ago
As of the end of June they significantly relaxed the rules around the path to citizenship, including dual citizenship. Anyone can now do it if the other country also allows dual citizenship.
I had no idea this was a thing. If you renounce your citizenship and you don’t yet have a new one… What a weird place to be in.
Yeah, being stateless is really bad. There’s a few international agreements to avoid the creation of more stateless people, but it still happens. You end up with people spending years in airports or jails as their visa expires and they have no way to renew it or get a visa for elsewhere, and asylum claims can take months to years to process, and get denied anyway.
Exactly what I was wondering, thanks. I assume you have to renounce before acquiring a new citizenship? No thanks.
No, other way around. Most countries won’t even allow you to renounce if you don’t have another citizenship.
The US also charges $10,000 dollars to accept your renunciation. The US is one of the few countries that taxes its citizens in foreign countries so there’s a big incentive to renounce when you get citizenship in a better place. There is a substantial tax deduction for the first ~150K you earn in another country, as long as you spend less than 10 days in America or traveling and pay taxes in that country, as long as that country has such an agreement with the US.
It’s $2350 to renounce, not $10k.
Most countries tell you to renounce after you gain the new so it isn’t a problem. A few allos dual citizenhip. (maybe most allow dual? I seem to recall that but it is outside where I’m sure)
If you do that couldn’t you just not let them know about the new citizenship? How does that work?
It’s very difficult to enforce. I’ve heard of cases where people like show the embassy a passport of a citizenship they said they renounced by accident, and were just sternly told to renounce it, other cases where their new citizenship was revoked.
generally it isn’t enforced
All the examples listed in Wiki seem very different from what OP is talking about. Most of the stateless persons are located in 4 counties. Crazy.
Countries typically don’t allow that. (Do any allow it?) For example, Canada requires you (at least) to be a citizen of another country and to live outside Canada.
The UN would likely consider it a violation of their human rights if a country knowingly allowed a citizen to become stateless. I would hope that at least all member states would not allow it, but I don’t know for certain.
The USA allows it. Though I imagine the embassy staff will probably try to warn you.
Usually your old country takes you back in that case unless there’s some problem like you married an ISIS fighter.
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Sovereign citizens, the kind that call themselves American State Nationals, do this by getting a special fake passport from this website that mostly sells moonshine supplies but sells fake passports on the side.
This doesn’t answer your question but I think it’s really interesting so just as an aside.
If you just tell Country B that you do so, like in an oath or something? No, no effects on the old country and they may even still want taxes from you.
If you contact Country A’s government (usually the state department or foreign ministry) and go through whatever process they have and pay a fee then yes. You will no longer have the responsibilities (taxes, military service, etc) or the rights, (voting, travel, education, etc) in regards to the old country.
Should you actually go through that process? Consult a lawyer in your new country to see if it’s necessary. Sometimes it’s better to keep the old passport, like if you’re a western expat. Sometimes you’re trying to get out from under international tax obligations or required military service. Regardless, the new country generally doesn’t care what the old country thinks as long as you follow the laws of your new country. Sometimes it’s a verbal promise to renounce loyalty and sometimes they want that receipt from the old country saying it’s done.
It varies from country to country. Some countries don’t let you become a citizen again after renouncing, while others allow it.
Citizenship is related to taxes (which also varies from country to country), so some countries are very interested in your citizenship in order to be able to establish that you owe them income taxes.
How would your previous country find out? I imagine it’s like any crime: you either do something to make it easier for them (try to renew a passport, fail to file a tax return) or they find you by accident (some investigator notices a connexion between two observations that makes their mind tingle).
There’s probably more, but that’s enough to answer your questions.
Does that have any effects back in country A?
Yes, you lose all the rights you have as a citizen. That means you’ll need a passport and/or visa to visit if one is required, you can’t live there anymore without a formal agreement like a work visa, you don’t get any health insurance offered, you can’t get government assistance, you can’t vote, you can’t own firearms if that’s allowed, and any other rights that citizens in your home country have. You are no longer a citizen.
This all requires positively going through a process. It’s not automatic.
Yes, renouncing your citizenship is a formal process.
Not all countries require you to actually go through the process, some just have it in the oath.
Depends on the country, but you will have to check with country B what form requirements they have for you to prove you did it.
Well if you’re an American, expensively.
The IRS is determined to make sure that they juice every last drop out of you to make sure that you feel the hurt, because Americans denouncing their citizenship are one of two kinds typically, either A) Political migrants who are renouncing to make a statement about some great failing of the US, usually something the feds have dug their heals in over like Vietnam, or B) Financial migrants who are trying to escape tax increases.
Either way, the feds have a vested interest in deterring that behavior as much as possible and so the US is one of the few places that gets away with enforcing an arm and a leg exit tax and IIRC still makes you pay another 10 years worth afterwards basically to punish you for trying to skip your duty to your fellow citizens to support the country and her infrastructure and services that everyone shares.
Elizabeth Warren had actually proposed tightening the noose even harder during the 2020 primaries because where Republicans loose their shit over the idea of women being able to outsmart abortion restrictions, Dems, and especially progressive Dems, loose theirs at the thought of some Elon Musk type being able to take the bag they made off American infrastructure and labor and run away with it to avoid paying the fair share back.
People usually call it brain drain but really it’s all down to tax dodging, between the high rate of immigration and envy of the world higher education quality (so long as you can afford it), America is not running out of smart people without a 20th century style purge of the “intellectual class” by authoritarian militias because smart people aren’t dumb enough to go along with their strong man fetish.
Tl;Dr, the IRS REALLY wants to make sure you know that renouncing for financial reasons is gonna be way more costly than what you’re gonna save by fleeing to a tax haven.
Yeah you didn’t remember correctly at all. The fee to renounce citizenship is ~$2300 for everyone. For the IRS piece, you file a final tax return the year you renounce citizenship, and they check to see if you’ve been compliant and paid everything you owe for the previous 5 years, but the exit tax only kicks in if you’re worth over $2 million, paid an average of a shitload of taxes (like more than twice the US median household income, so most people aren’t going to qualify) over the previous 5 years, or don’t certify that you’re in compliance. IF you have a lot of money, they treat it as though you’ve sold everything you own and calculate what that would be worth, deduct $821,000 (as of last year), then tax the rest of the amount they calculated. Then you’re done, unless you happen to have US income after that.
