Talk:Multiple citizenship

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I removed the following dubious assertion:

Some, if not all, unitary states permit only one citizenship. Other states (e.g. federal nations) permit dual or multiple citizenship.

The Republic of Ireland is a unitary state permitting dual citizenship; Germany is Federal republic not permitting it. Joestynes

Germany does allow dual citizenship in certain circumstances. EG a child born in the US to German parents will usually have dual US/German citizenship. And Germans wishing to naturalise elsewhere can keep German citizenship provided they get permission to do so in advance. JAJ 00:41, 21 August 2005 (UTC)

Whilt what JAJ says is undoubtedly true, that doesn't negate the comment made above about the fact that the assertion in the article about unitary states and federal states being dubious. ---

Some of this page seemse to be a copyright infringement from Multiple citizenship. That site explicitly says it's for Non Commercial use, which I think excludes its being here unless the copyright owner says otherwise. Could someone else please do what you're meant to? Felix the Cassowary 11:30, 7 Mar 2005 (UTC)

--- I deleted some information that I felt was irrelevant and redundant, namely the subjective statements about restrictive citizenship policies in Australia. Since the 2002 overhaul, Australia explicitly allows and recognizes plural citizenship. Also the middle section appears lifted and one paragraph was a near copy of another paragraph. I hope I don't offend the original author in my edits. I think this article needs furthur clean up. Also, there should be sources to the "Incidence" section. K 14:30 10 Mar 2005 (UTC)

It's also worth noting that in various circumstances, dual/multiple citizenship was perfectly legal and accepted under Australian law even before the 2002 overhaul referred to above, so these subjective statements about restrictive citizenship policies in Australia are well removed. RW 2 April 2006

Contents

[edit] Greece

According to this article: http://en.wikipedia.org/wiki/Greek_nationality_law Greece has dual citizenship. The map needs to be updated.



[edit] List of countries not permitting multiple citizenship

Can we add a list of countries which don't allow multiple citizenship? I know of China, Japan, Belarus. What others are there?

  • A nieve question: If you are a citizen of a country which doesn't allow multiple citizenship, and you apply in a new country for a passport, does that country have to tell your home country that you've applied. ie. Could a Japanese person have a US passport and citizenship, and simply not tell the Japanese government? How would they ever know? Seabhcán 11:04, 16 August 2005 (UTC)
Here's an example. Each time a German citizen living in Canada applies to renew his German passport, he is required to obtain a recently issued letter from Canada Immigration stating that he has NOT obtained Canadian citizenship.
Addtionally, when some countries grant citizenship to a person they will advertise that person's name (and/or country of birth) in some type of publicly issued government announcement. A country that actively wants to minimize dual citizenship could be searching such a publication. Steggall 14:30, September 7, 2005 (UTC)
  • the law of some countries revokes citizenship automatically in these circumstances. So in this situation, depending on what Japanese law says, the person might be illegally holding a Japanese passport. JAJ 00:39, 21 August 2005 (UTC)
  • I think it's wrong for any country in the world to deny its citizens the opportunity to hold multiple citizenship. No wonder people have to agonize over what citizenship they have to give up. What if a citizenship is automatically acquired at birth, a problem ethnic Arabs face. See the articles South Korean nationality law and Japanese nationality law for more info on the problem some Arabs born in those countries face. (Unsigned, 15:20, 25 November 2006 Dwainberg)
Be that as it may, the point of Wikipedia is not a blogish exchange of views on issues. -- Boracay Bill 14:01, 25 November 2006 (UTC)
  • Furthermore, most Arab countries and territories--autocratic (e.g. Algeria, Morocco, Tunisia, Libya, Egypt, Jordan, Oman, Qatar and Syria) and democratic (e.g. Palestinian Territories, Lebanon) allow their nationals to hold multiple citizenship. See [1] and [2] for more info. Why can't democratic countries that set a maximum age for their nationals to hold multiple citizenship e.g. Germany, Japan and South Korea follow their Arab cousins? Ambassadors from those countries who have diplomatic missions in Germany, Japan, South Korea and others in their position will thank them immensely. Politicians in the three non-Arab countries I've mentioned above should make some noise in their national legislatures and, if necessary, introduce private members bills that would allow foreigners living in such countries the opportunity to acquire the citizenship of their country of residence. (Unsigned, 15:20, 25 November 2006 Dwainberg)
Reiterate my comment above re blogishness. -- Boracay Bill 14:01, 25 November 2006 (UTC)
  • I'm from Northern Ireland and I dont like to be called a "Northern Irelander" I'm Northern Irish,also I would like to point out that we are not "De facto" Irish Citizens,being part of the United Kingdom we are British Citizens like any other person just by being born in any other Part of the United Kingdom being it England,Scotland,Wales, or Northern Ireland, the article it self says that we are de facto Irish citizens..this is wrong ..as its says in the Irish Citizenship laws that any one born on the Island of Ireland has an ENTITLEMENT to Irish surely an entitlement means something you can have if you want it so until someone like myself actually gets a application form for a Irish Passport fills it out sends it off to Dublin then gets their Irish Passport in the post 2 wks later thats excising my "Entitlement" to Irish Citizenship so until then we aint de facto Irish Citizens though the Entitlement is there for anyone Born on the Geographical island of Ireland —The preceding unsigned comment was added by Scales67 (talk • contribs).
I've changed the wording to something more neutral. It's worth noting that not everyone from Northern Ireland is entitled to Irish citizenship - for example, immigrants who have become naturalised British citizens do not have that entitlement. Also, there are some cases where children born in Northern Ireland with parents are neither British citizens nor permanent residents may be Irish citizens but not British citizens (at least not at birth, there are ways to acquire British citizenship later). The Irish have changed their law from 1 January 2005 - for those born on or after that that date, birth in the Republic of Ireland or Northern Ireland is not enough in itself to create an entitlement to Irish citizenship. JAJ 00:13, 16 April 2006 (UTC)

I agree with the original poster that we should create a list of those countries that do and do not support dual or multi citizenship. Any other takers?--Saintlink 03:57, 10 September 2006 (UTC)

That won't work because in most cases the answer is much more complex than "yes" or "no" JAJ 23:42, 10 September 2006 (UTC)

Pardon me, I should have clarified a bit better. I meant to say "create a list of all the countries and their various dual citizenship policies." As the list would get to be quite long, I suggest we categorize it on another page. We would just list all the countries in alphabetical order and then create each article as we go. Does that sound agreeable?--Saintlink 14:02, 11 September 2006 (UTC)

Isn't this best addressed with the nationality law article for each specific country? JAJ 00:48, 12 September 2006 (UTC)
In this regard, the recent similar-case example in Status of religious freedom by country having been forked off of Separation of church and state is instructive (though not, IMHO, as a template to be followed). -- Boracay Bill 02:32, 22 November 2006 (UTC)

[edit] Links

I reverted the link addition again, because I feel it is more in line with Wikipedia policy. I think this is getting close to the "excessive lists can dwarf articles" point. When do we stop adding countries? This is not the place for this list IMHO. Some of these links don't even talk about dual citizenship per se. Of course information is good, but Wikipedia is not set up as a search engine. If someone wants information on a particular country, they can then go the country's website directly.

This is my feeling anyway. If the community thinks these links should be here, that's fine with me. They were only added recently. --PhilipO 16:24, September 6, 2005 (UTC)

I'm going to restore the links. If they don't belong here, where do they belong? They are not always under the individual countries. The link on Irish citizenship was originally on the Ireland page. Someone over there decided that wasn't the place for it.
I'm a firm believer that information is good, and more information is better. So, rather than worrying about pedantic rules let's make the information available. Irish Hermit 01:36, 7 September 2005 (UTC)
Well, you've answered the question yourself. They belong on the individual country pages - particularly the UK link which hasn't much to do with multiple citizenship per se. Cheers. --PhilipO 01:53, September 7, 2005 (UTC)

[edit] Sub-national citizenship - US state citizenship question...

This section states that 'state citizenship' is obtained by becomeing resident of the state. Does this apply to non-US citizens? Ie. Is a Mexican who is legally resident in Texas a citizen of Texas, but not a US citizen? Or should we qualify the statement by saying that "A US citizen obtains a state citizenship by becoming resident there." Seabhcán 09:45, 6 October 2005 (UTC)

[edit] Map is Incorrect

Brazil does allow dual citizenship; the map says it does not. Anyone mind changing it?

Some sources: http://www.aph.gov.au/library/pubs/CIB/2000-01/01cib05.htm (table 1) http://www.capriotti.com/dual.htm http://www.uscitizenship.info/citizenship-library-dual.htm —The preceding unsigned comment was added by Dan1113 (talk • contribs).

Would you mind providing some first-hand sources? Not other government's pages and commercial websites? Cheers. +Hexagon1 (talk) 09:37, 11 April 2006 (UTC)
http://www.brasil.org.co/htm/consularbr5.htm "Não há qualquer restrição quanto à múltipla nacionalidade de brasileiros que possuam nacionalidade originária estrangeira, em virtude de nascimento (jus soli) ou de ascendência (jus sanguinis). Isto significa que todo indivíduo que, no momento de seu nascimento, já detinha direito a cidadania diferente da brasileira, reconhecida por Estado estrangeiro, poderá mantê-la sem conflito com a legislação brasileira."
It says that there is no restriction on multiple citizenship if you were born with the right to have a citizenship of some other country (by birth or parents, etc).
In the summary (EM RESUMO), it says that again, but it says that you cannot have dual citizenship by marriage to a foreigner, just by location of birth or by family line (parents etc). (I suppose it also means that foreigners going to Brazil can get Brazilian citizenship and keep the other since the other was gotten by birth. Well, not just 'suppose' -- I know this is the case with quite a few people (and going the other direction too).)Dan1113
Okay dokay, I'll change it. You need to flush your cache to see your changes. +Hexagon1 (talk) 10:03, 12 April 2006 (UTC)
I think a few more changes are needed:
* Iceland does allow dual citizenship since 2003. Icelandic nationality law
* I'd think India is more a "no" than a "yes". Indian nationality law
* I haven't got specific references at the moment, but as far as I understand it, Poland, Croatia and the Philippines do allow dual citizenship.
* the eastern half of Tierra del Fuego should be colored the same as mainland Argentina. JAJ 00:19, 16 April 2006 (UTC)
I've recoloured India, Iceland, and what I assume is Tierra del Fuego (the formely green thing under Argentina). I can't recolour Poland, Croatia and the Philippines without references, though. Thanks for the notice. +Hexagon1 (talk) 11:22, 16 April 2006 (UTC)
* Poland appears to be more "yes" than "no" [3] and [4]
* Croatia is more "no" than "yes" so the map appears to be correct Details
* Philippines appears to be more "yes" than "no" (laws changed in 2003) Details JAJ 15:08, 16 April 2006 (UTC)
"A Polish citizen may gain foreign citizenship with full effect under Polish law once he/she receives a permission to renounce Polish citizenship granted by the President of the Republic of Poland." - I'd say that's a no, and I've recoloured the Ph's. +Hexagon1 (talk) 15:43, 16 April 2006 (UTC)
What it seems to mean is that a Polish citizen who becomes a U.S. or Australian citizen keeps their Polish citizenship unless they voluntarily renounce it, hence the "yes". The fact that Poland doesn't "recognise" dual citizenship is not really relevant, most countries don't do so even where it's allowed, eg Master Nationality Rule. JAJ 17:19, 16 April 2006 (UTC)
The text states they may acquire other citizenship once they receive a permission to renounce Polish one. +Hexagon1 (talk) 05:09, 17 April 2006 (UTC)
I think you're looking at this the wrong way. If a Polish citizen wants to become Australian and keep Polish citizenship, then he does not need any permission - he can become Australian and Poland will continue to treat him as if he was solely a Polish citizen (so he must enter and leave Poland on a Polish passport). This is just like what the U.S. does with Americans who naturalise elsewhere, the U.S. (like Poland) doesn't recognise dual citizenship but because it does not revoke the nationality of Americans who naturalise elsewhere it allows dual citizenship. JAJ 12:24, 17 April 2006 (UTC)
OK, I didn't pay adequate attention to the "may gain foreign citizenship with full effect under Polish law " bit. You can change the map or I'll do it tommorrow, it's 4 am. (note the map is really at commons) +Hexagon1 (talk) 18:12, 17 April 2006 (UTC)
Venezuela allows multiple citizenship since December 15, 1999 ( http://www.embavenez-us.org/constitution/title_III.htm, article 34) JRSP 02:57, 10 July 2006 (UTC)

Netherlands allows multiple citizenship as well...

[edit] UK/US citizenship

Could I please get a source on the part about is a US citizen living in the UK 5 yrs automatically gets dual citizenship.Jim Bart 21:11, 11 June 2006 (UTC)

Such a person wouldn't "automatically" have dual citizenship. After five years of residence, the person could apply for natrualisation in the UK. Once the naturalisation was complete, he would then have both British citizenship, and his original US citizenship, and therefore be a dual citizen. Steggall 23:47 11 June 2006 (UTC)

[edit] Problem talking about "recognition" of multiple citizenship

The term "recognise" is potentially ambiguous in a discussion of multiple citizenship. Some (probably most) people will be thinking of whether a given country allows its citizens to hold additional citizenships — but others will assume the term refers to whether a given country acknowledges (or cares about) the fact that one of its citizens might also have another citizenship (i.e., whether or not a country gives any different status to one of its citizens if he/she also has citizenship in some other country).

In order to sidestep this potential for confusion, I would recommend that most (possibly all) uses of "recognize" in this article should be replaced with "allow" or "permit" — since that's what is really being discussed (does a given country allow one of its citizens to also be a citizen of another country?).

Admittedly, I have read of a few cases where the other kind of "recognition" of multiple citizenship exists — e.g., treaties where Country X agrees not to assert its own citizenship claims against one of its expatriates who enters on a passport from Country Y — but that's a very different matter.

Richwales 18:37, 12 July 2006 (UTC)

I agree, I haven't noticed this. +Hexagon1 (t) 23:32, 13 July 2006 (UTC)

This whole area of countries "recognizing" foreign citizenships or "allowing" their citizens to hold foreign citizenships needs a look. I don't have legal training, but my understanding is that countries may be able (1) to administratively strip their citizenship from someone who holds it and/or (2) to punish persons (e.g., citizenship restriction violators) who they feel need punishment where they have the ability to impose punishment (e.g., the person has local assets which can be seized, is physically accessible for imprisonment, etc.), but not much else. Also, (unrelated) this article seems to use the terms citizen and national somewhat interchangeably. My understanding is that these terms are not interchangeable, and that their definitions may vary from country to country. -- Boracay Bill 02:56, 22 November 2006 (UTC)

There is now a para in the intro on this issue. In most cases, what is being discussed as "recognizing", allowing, etc., boils down to not actively stopping - either legally or in practice, and multiple citizenship may exist in practice, but not in law in many countries.--Gregalton 07:13, 22 November 2006 (UTC)

I have reinstated slightly modified text that was objected to on the basis of the para containing a tautology. I disagree with the assertion that "permitting" and "not forbidding" constitutes a tautology; this is not a core tenet in some legal systems, and they are separate concepts. To give a specific example, parking may be permitted but regulated. That said, I've substituted the word recognized to make clear the distinction. The issue remains because in many cases (including this page), in popular discourse discussion of multiple citizenship often refers to "Country X allows/permits/recognizes" multiple citizenship where there may be no such legal concept.--Gregalton 07:13, 22 November 2006 (UTC)

I agree with many of the comments, which reflect the complexity of the issue. Indeed there seems to be a gradient of how another citizenship is treated; on a descending scale of permissiveness: recognize (the citizen can be treated as a citizen of another country if they so desire), allow =~ tolerate =~ ignore, and forbid. 'Forbid' may also mean a number of things. Similar ideas were expressed below under "Edit the map", and some of this could be elaborated upon in the text if the senior contributors don't object. I've tried to clarify a few points by editing the introductory paragraphs. I replaced the example of Singapore and Japan, from which it is not clear of what exactly those countries do, with more specific illustrations. I am new here, and I hope that I am not stepping on anyone's toes. Dr.007 01:03, 4 January 2007 (UTC)

[edit] Canada's Governor General Edit

Removed a bracket explaing that Michaelle Jean renounced citizenship, but could reclaim it at the end of her term in 2008 due to her "diplomatic immunity". This was incorrect for many reasons:

1) She is not a diplomat.

2) She was appointed in 2005. A five year term would end in 2010, not 2008, but see below.

3) She does not have a term. GGs serve, to quote the Letters Patent 1947, "at His Majesty's pleasure". Five years is traditional, but it is not a term.

4) That bracketed comment was nonsensical. How does diplomatic immunity allow someone to recover citizenship?

—The preceding unsigned comment was added by 72.1.218.17 (talk • contribs).

[edit] Edit the map

Could someone with the necessary skill level please edit the map by changing Taiwan from red to yellow?

How about editing the map so that the countries are classified into 6 categories, with countries classified under different categories highlighted in different colours:

Concerning point 4, Germany only has age limits for multiple nationals born on German soil who would not have otherwise inherited German citizenship. German nationals who were born in foreign countries and inherited nationality from either parent aren't restricted. 69.151.233.215 01:48, 5 January 2007 (UTC)

--- In the image in this article, Spain is shown in red, indicating that they do not allow dual citizenship. However I am a dual citizen of Spain and the United States so I know this to not be true. Please fix this! --- —The preceding unsigned comment was added by 192.136.22.4 (talk • contribs).

Hmmm.... The map does appear to be incorrect in re Spain. Section 11 of the Spanish constitution reads:

Section 11
1. Spanish nationality shall be acquired, retained and lost in accordance with the provisions of the law.
2.No person of Spanish birth may be deprived of his or her nationality.
3.The State may negotiate dual nationality treaties with Latin-American countries or with those which have had or which have special links with Spain. In these countries Spaniards may become naturalized without losing their nationality of origin, even if those countries do not grant a reciprocal right to their own citizens.

  • 11(1) says that the constitution is not the final word on this. Ordinary laws might specify anything at all regarding Spanish nationality.
  • 11(2) implies that a person of Spanish birth (not sure what "Spanish birth" means - born on Spanish soil? Having a Spanish parent? Something more complicated?) is a Spanish national, and says that such a person may not be deprived of Spanish nationality.
  • 11(3) speaks of the possibility of dual Spanish/Other nationality, and apparently contradicts 11(2) by mentioning the possibility of loss of Spanish nationality.

The above is confusing, but it does appear from 11(3) that Spain should not be colored red on the map. I think that the map should be removed, as the question Does this or that country "permit" multiple citizenships? more often than not does not have a black & white answer which can be accurately shown in red vs. yellow. -- Boracay Bill 22:49, 30 March 2007 (UTC)

[edit] Argentina

Can anyone confirm that Argentina does not allow multiple citizenship? It is common in people with european ancestors to have argentinian citizenship (by being born there) and one european nationality (obtained for being a child of a foreigner). If there is such a law, it is completely ineffective.

[edit] The Sub-national citizenship section

Let me take the first entry in this section bit by bit:

I think this is a stretch. I don't think there are any dual-citizenship issues between the U.S. national government and the governments of any of the several states.
  • State citizenship, however, is informal in practice, and is obtained simply by taking up residence in any given state.
Residency requirements for state citizenship vary state by state. I looked at some (not all) state constitutions, and see that some confer state residency after some stated period of residence in the state on persons who are not U.S. citizens.
I don't think the absence dual-citizenship is an issue is deserving of a mention here. Also of note, (and also not an issue here) residents of (some?) U.S. territories and possessions become U.S. citizens by birth, similarly to persons born in the District of Columbia.
  • There is now almost no legal bearing brought by such an arrangement, except possibly for interstate extradition.
Article V Section 2 of the U.S. Constitution (as amended by Amendment XIII) reads:
The Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States.
A Person charged in any State with Treason, Felony, or other Crime, who shall flee from Justice, and be found in another State, shall on demand of the executive Authority of the State from which he fled, be delivered up, to be removed to the State having Jurisdiction of the Crime.
  • <!-- Residency requirements for political candidates almost never refer to the term "citizenship" anymore. -->
Not true. One example at [16]

Perhaps this first subsection should read simply:

  • Under the U.S. Constitution, all persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. -- Boracay Bill 04:42, 22 November 2006 (UTC)
Agree, this is overly long and not of interest here. It should be in an article on the U.S. instead.

[edit] Germany and Age Limitation

I invite all of you to read the excellent article on the German nationality law before deliberating on Germany's multiple citizenship policy. The age limitation provision applies to those who became German by birth, and not citizenship by descent. In other words, a person born in the USA to non-naturalized German parents remains a German citizen for the duration of their life, while a child born to foreigners in Germany must choose at the age of 23 or lose German citizenship. 69.151.233.215 02:07, 5 January 2007 (UTC)

[edit] Examples

What purpose does the Examples section serve? There are countless possible scenarios where persons may acquire multiple citizenships, and those provided are not particularly instructive and presented in a haphazard fashion. I find that it is sufficiently clear in the opening section how multiple citizenship comes about. Readers wishing to find out more about specific countries can easily follow the links to articles about their nationality laws. Kraikk 12:44, 3 April 2007 (UTC)

I think the Examples section does serve the purpose of illustrating the fact that multiple citizenship is more common than most realise, it also gives a sense of globalisation of today's world. However, some of the similar examples can be removed. Four of the examples deal with a birth of a child to parents of different citizenships in a third country. We probably want examples that simultaneously illustrate multiple issues like naturalisation, jus soli, jus sanguinis, citizenship by descent, sub/supranational citizenships, and citizenship in territories with multiple claims on sovereignty. A good example should be generic enough that it is the case actually experienced by hundreds of thousands of people. It should been shown how these issues are applied in each case. --Kvasir 08:04, 6 April 2007 (UTC)
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