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Guide to Living and Moving Abroad With or Without Dual Citizenship

Know Your Rights

It is often desirable for citizens to hold dual passports.
Holding dual passports is often better than having just one if you wish to move abroad.

There must be a good reason for having two passports. Ex-Prime Minister Tony Blair, his wife, and all four of his children have Irish passports in addition to their passports from the U.K. This is thanks to Mr. Blair's Irish grandmother.

Americans are increasingly applying for and getting passports from other countries. Many US citizens are under the false assumption that it is illegal to have foreign passports. It is not.

Americans Eligible for a Second Citizenship

It is difficult to get an exact fix on the number of Americans with a second citizenship. 40 million Americans are eligible for a second citizenship; most because of parental or grandparental ties.

Currently, just over 37% of Americans have a U.S. passport. And now, Americans must have an official document to travel to Canada or Mexico.

Passports are held by only 42% of American citizens.
U.S. Passports are held by just over 37% of American citizens.

Procure Two Passports When Possible

Most travelers in the know want to make sure they have two passports if possible — especially a passport from the E.U. It allows an American, Australian, or Canadian citizen to work relatively hassle-free in the E.U. There are safety considerations as well. I have had an Irish passport and my US passport for years. I'd rather travel with an Irish passport in Pakistan or Iraq than an American one. In my case, the motivation was to teach in Europe.

Once I'd received my K-8 teaching certificate, I spent seven years teaching in the U.S. But I'd traveled to Europe before and felt close to it. I decided to let my Irish background work for me. I requested the forms, did the paper chase, and in 1980, got a letter from the Consulate General of Ireland in Chicago.

"I wish to inform you that it has been granted. The cost of Irish Citizenship is $12.50. Please let me have a cheque…" This was a bargain at half the price. I have lived, traveled, and worked in Europe for almost 20 years. I consider that $12.50 is one of my best investments. I know many others would like to do the same. Is it possible? Yes, it is. I hope the following helps others to realize the same possibilities. But I am not a lawyer nor an expert. The information comes from official U.S., Irish, U.K., Canadian, and Australian websites and phone calls with embassies in Madrid. But you must also check for the most current information for your specific case.

The process can be straightforward. But once one gets into more involved conditions of living overseas, only a professional or embassy can give you the reliable information.

Q & A

1) Is it legal for an American citizen to be a citizen of another country and to hold two passports?

Yes, with conditions. Suppose you have dual citizenship from birth or have become a citizen of another country, even after having U.S. citizenship. In that case, U.S. law, even going back to the Constitution, offers you the right to keep both citizenships for life. This assumes that the second country has no law requiring you to renounce a previous citizenship. And even then, the US might need to recognize the legality of such renunciation.

For some years, the U.S. State Department was a stickler on the rules concerning the right to own two passports. And some officials will still claim that you can't have both. But such is not the case.

It becomes less clear if the person obtained was naturalized in the U.S. but still wants to claim the original citizenship. The naturalization process requires the giving up the old citizenship. But even then, the first country might not recognize the U.S. requirement of renouncing said citizenship.

However, the U.S. often disregards the strictest requirements of the birth or a second country's oath requiring a person to renounce their U.S. citizenship. It is rather challenging to say, "I am not a citizen of the U.S." More on that later.

2) Will a person lose their citizenship if they move to another country with the idea of living there or taking a long-term job there?

No. The developed world now sees that its borders are more open than ever. The E.U. sees people coming and going all over it.

3) I thought that the U.S. Constitution forbids being a citizen of two countries?

And I bet you thought the Constitution made English the official language of the U.S. No, The Constitution says nothing on the topic. (The U.S. has no official language at the national level.)

4) Is there a difference between nationality, naturalization, and citizenship?

I think so. I had Irish nationality because of my parents. But I was a citizen of Ireland when I applied for it. Citizenship implies legal obligations. Naturalization is the process one goes through to become a citizen of another country. Not everyone with whom I have makes this distinction — but dictionaries do.

One online dictionary defines nationality as "A people having common origins or traditions…, or a national character." If one is a citizen, one also has legal obligations: paying taxes or, perhaps, even military service. In any event, I use citizenship here to mean the legal connection between a person and a country.

5) If I am both a Spanish citizen say, and a U.K. or U.S. citizen, am I required to pay taxes in both countries?

Yes, you are. While the U.S. puts a very generous upper limit after which you have to pay taxes, you still have to declare. The limit is far beyond the wildest dreams of most independent travelers or teachers. But an Irish citizen does not have such a limit. Again, check with your tax people.

6) What if, in order to get the citizenship of a second country, I have to renounce my original citizenship?

This is a very cloudy issue. Firstly, most E.U. countries won’t require it. Spain requires that an adult be Spanish except with the exception of Argentines. But with a citizenship gotten through parents or grandparents, you are probably OK. Even then, one of the embassy people I spoke with said that the renunciation might not be recognized by the first country.

7) Could I unknowingly lose my original citizenship when I have a second?

It’s possible but very unlikely. When I got my Irish citizenship, I received a letter from the U.S. Department of State. “It has come to our attention…that you have become an Irish citizen. It is possible that by performing this act you may your lost your U.S. citizenship” etc. But I and thousands of others have not. See the last section for more on that theme.

(I didn’t have any obligation to inform the government of my step. But governments keep in touch. The Irish authorities had told the U.S. That seems typical.)

8) Citizens in the other major English speaking countries?

Since the Irish immigrant is such a stock figure in other countries, his children or grandchildren have the easiest time getting an Irish/E.U. citizenship. It carries many of the same benefits as the others. An added bonus is that they don’t have to pay taxes on overseas earnings. And for travel in problematic areas, it’s a far safer one. The Irish military of 8,500 people is involved in peacekeeping missions only. And Guinness has been a good will ambassador in over 200 countries, so most doors will be open.

Ireland does not require any foreign citizenship to be renounced on becoming a citizen. Most new citizenship is through descent. It does require the paper chase and there is a small fee.

9) The U.K.?

The British Nationality Act was passed in 1948. In general, there is no restriction on a U.K. citizen to become a citizen of a second country. Unlike some other embassies with whom I talked, the U.K. is a bit stricter regarding what happens to a U.K. citizen if they assume citizenship in a country that requires renouncing any other nationality. For example, if one is a U.K. and U.S. citizen (which requires renouncing other citizenships), the situation could arise where the U.K. consul might refuse help to a U.K. citizen in the U.S. So again, check first.

10) Australia?

Prior to the pandemic, Australia was a land of recent immigration. It takes an open attitude to the idea of dual citizenship. In fact, their website says that many Australia might be dual nationals already without knowing it.

They add that one can be or become a dual national by birth, by descent, by marriage, or by naturalization. It adds that the same negative consequences might apply to an Australian dual national traveling to their second country: military obligation (such as Egypt, Greece, Lebanon and most countries in Central and Eastern Europe), non-recognition of Australian citizenship, etc.

Since April 2002, an Australian has been allowed dual citizenship but a person is strongly advised to check with both the Australian Department of Foreign Affairs and Trade and with the embassy of the second country concerning questions on a passport and travel.

11) If I live in Canada?

Why a Canadian would want to travel away from that country is a mystery. The government allows dual citizenship. But many cautions that apply to Australia, the U.S., etc., also hold there. You can get much more information from their website. (See box-out below.)

12) If live in London?

It's far easier to see why a person living in London might want to spend time working or retiring to Spain or Greece. And before Brexit, they were already E.U. citizens and enjoyed many of the same rights and privileges.

Since Brexit, much has changed, with work, living, and some aspects of travel to many E.U. countries seriously curtailed. While there are some differences in the ability to gain the right to live, work, and even travel for longer than more than three months in certain E.U. countries, it is best to start by reading the U.K. Parliament guide "After Brexit: Visiting, working, and living in the E.U." — which discusses the consequences for U.K. citizens. The guide also addresses those wishing to work, move, and live in the U.K. from the E.U. Check with your embassy for the latest information due to the recency of the changes.

In addition, many companies in the U.K., including major banks, have moved their headquarters before, during, and after Brexit, meaning there are many economic and long-term business travel changes as a result.

Can You Lose Your Nationality by Working and Living in Another Country?

One of the most frequently asked questions about having a second citizenship is if one could lose their first nationality by working and living in a foreign country. It's improbable. One has to be very specific about wanting to renounce a first citizenship. If there is no intent, there is usually no risk.

In the case of my U.S./Irish citizenships, the U.S. State Department advised me that I might lose my citizenship by voting in Ireland (not possible yet from Spain), serving in its armed forces (highly unlikely), or holding any post that required that I pledge allegiance to the government.

I won't touch on marriage with foreign nationals or children born overseas to dual citizens. It's simply too complex for this article.

In conclusion, I'm still a foreigner living in a second country for over 20 years, marrying a local, sending my child to a local school, and paying taxes. But the second passport has allowed me the space and convenience to enjoy all that a different land offers, whether Spain, Thailand, or Brazil. The benefits far outweigh the unlikely downside. Go for it.

More Information on Dual Citizenship Opportunities

What's in a name? Everything if it's one way on your birth certificate and another on a passport or other legal document. If your friends call you Spike, but it's Mortimer on your birth certificate, it has to be Mortimer on your passport.

The name on your passport should be the one that you are known by and is your legal and current name. A friend wanted the Irish of his name on his new passport. The embassy refused, saying it was not the name he lived by. It was good advice.

Use your birth certificate as your benchmark. If you have changed your name because of marriage or by court order, etc., have copies of all relevant paperwork with you as you travel and ensure that your passport has that name. In that case, it might be different from your birth certificate, but you must be able to document that fact.

And even within the E.U., names from other cultures cause a delay in processing paperwork. In my case, I have two first names and a last name. And the spelling of my last name, McGuire, can give pause to some. In Spain, my second name became my last name, while my last name became the second part of my last name. The Spanish habit is to have one first name and two last names.

Be patient with embassy people and border guards. Their job is to follow procedures based on their culture rather than yours. You will make their job easier by having clear documentation and a lot of patience.

The advice I read the most is to be sure that your name is the same on every legal and travel document, from your passport to your airline ticket.

Key Resources for Dual Citizenship

The first thing to do to determine if you qualify for a second citizenship/passport is to talk to your parents and grandparents. One of the easiest and most common ways to get dual citizenship is through foreign-born family members. The second way is to check your country's embassy/consular/government website. They offer a world of information. In preparing this article, I was impressed with the helpfulness of the Australian and Canadian embassies. All the Anglo-speaking countries have web information that can be very helpful.

For example, the relevant resource for Australia is the Australian Government: Australian Citizenship section. The relevant website government website for citizenship in Canada provides detailed information on your options.

Non-governmental sites sometimes offer helpful info. Do be careful. When you search "second citizenship countries," you get an extensive list of matches. But some want to sell you a passport, claiming that one from the former U.K. colony of British Honduras is acceptable. I do not wish to pay money for such services.

Keep in mind that gaining dual citizenship is easier in some countries more than others. Here are six countries where you might find it easiest to obtain a second citizenship, including Italy, Ireland, Israel, Paraguary, Guatemala, and Dominica. There are even many options to gain a second citizenship by investment, if you have the means. Keep in mind that if you are a U.S. citizen, you will have to continue to pay U.S. income taxes regardless of where you reside.

Wikipedia has pages on second citizenship and passports which is interesting for context, but do double check any information provided, as country regulations are complex and change regularly.

 


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