Legislation has been introduced into the Senate that would eliminate the right of American citizens to hold citizenship in another country. The only way to do so would be to give up your US citizenship.
It's a far cry from becoming legislation or even making it to the floor of the Senate, but it is something to be aware of.
Both Melania Trump and Barron Trump are dual citizens--the USA and Slovenia.
If find it difficult to understand how one can be both a Cleveland Browns’ fan (on the side of Goodness and Light) while at the same time being a fan of the Pittsburgh Steelers (on the side of Badness). Yet I have come to terms with this and now can accept folks who are both— hence Dual fans. Likewise I can forgive the Seattle Mariners for stealing Naylor from the Guardians however politely it was done and whether intermediaries were involved.
For travelers, potentially losing the ability to double flag is not good. Not a fan of that, I daresay. It may make my learning French in order to more effectively boycott Ryanair and Airbnb more challenging. Although I’ve come to accept Ryanair’s low prices are a boon to some consumers and Airbnbs have their place so long as they are not gobbled up by foreigners and big money out of towners in city centers. What did Aristotle say? Moderation in all things — except German pretzels and beer. (They are just too tasty.)
Somehow I suspect the Pittsburgh Steelers outfit is behind this!
Happy travels.
I think pretty much all the Americans (and Canadian) I've met that live over here have been dual citizens. Would be a bit of blow. Still, it would free them up from having to file taxes in the US even though they don't earn any money there.
David, your sportsball allegories go right over my head. I'd never heard of the Seattle Mariners until Webmaster's thread a short time ago. They sound like a proper bunch of salty seamen. My kinda guys.
As a straw poll, how many US citizens here would want to renounce citizenship if they permanently located to, say, the UK?
I don't speak football or whatever sport you're all referring to, but as a dual citizen this struck panic in me - and then I remembered that most of the ideas they have don't pass.
They could certainly pass a law restricting US Citizenship as a sole requirement. Right now there is no law either way, allowing or disallowing, just legal precedence and policy.
Though it is clear that the effort is more about "them foreigners" coming in and keeping their original citizenship as well as picking up US citizenship, than the travelers on here that picked up an "old world" passport by choice, for convenience.
Paul, I am one of "them foreigners" who immigrated to the US and subsequently became a US citizen while also retaining my original citizenship. It has nothing to do with 'convenience' for travel.
It would be interesting to know the motivation behind the foreign-born Senator's initiative. But noting that support from the money people is unlikely since there are plenty of them who take advantage of dual citizenship.
Dual citizenship can make travel more efficient and allows people to own property or operate businesses in another country.
The logistics of renouncing the US citizenship will most likely make this unrealistic. In Canada alone there are estimated to be 1 million with US dual citizenship. To renounce can take 2-3 years, as you. need to have an appointment at the a US embassy which can take that long to get, have all your US taxes completed and pay $2350 US to renounce. They would have to dramatically alter those requirements to make this work.
I somehow doubt that a lot of dual citizen 'ex-pats' who have retired to their 'other' country would be willing to give up their SS income which would disappear without US citizenship. I know I wouldn't. Of course if you don't need your SS, then maybe it would be ok.
You can definitely see how dual citizenship can work for a lot of people.
The US is one of only two (I think) countries in the world that taxes their citizens regardless of their country of residence. Meaning, if you hold a US passport, you need to pay your US taxes. I find it hard to believe the government would jepordize loosing this income. Forcing US Citizens to relinquish their citizenship will also be a difficult hurdle as it would require constitutional changes. While I don't love that this was bill was presented (especially as a dual citizen myself), I have a hard time seeing this gaining any meaningful traction. But, I could be way off...
Interesting. THE U.S. taxes my US and my Hungarian earnings and Hungary taxes both as well. EDITED
According to AI, which is never wrong:
Hungary: Hungarian citizens with dual citizenship and without a permanent residence in Hungary may be exempt from citizenship-based taxation. However, as a general rule, residents are taxed on their worldwide income.
Finland: A "three-year rule" applies to Finnish citizens who move abroad, during which they are still considered Finnish tax residents and liable for worldwide income tax. This can be challenged by demonstrating no close ties remain with Finland.
Philippines: While some sources indicate the Philippines once had citizenship-based taxation, more recent information suggests it taxes resident citizens on their worldwide income, while non-resident citizens are taxed only on income from Philippine sources.
Just out of interest. If I have US and French citizenship and I'm living permanently in France, earning an equivalent income of US$100,000 per year and no investments. If I pay the required tax in France, how much tax do I roughly have to pay in the US? And does still having a home in the US make any difference?
I am a dual citizen and have no intention of ever giving up either citizenship (and may even take on a third).
To respond to some of the queries about taxes- yes, it is correct that the US and Eritrea are the only countries that operate a citizenship-based tax system, rather than residency based. Some US politicians have been advocating for move to residency-based but I have no idea how likely that is to ever pass.
If your country has a tax treaty with the US (most European countries do), then the tax you pay in that country is netted off what you owe in the US, up to a certain amount. For me, I do have to file US taxes every year but I never actually owe anything. What's annoying is paying a service to help with the paperwork. In certain situations you do wind up with large tax liabilities- it's actually the reason Boris Johnson renounced his US citizenship several years ago, as he wound up with a big US tax bill after the sale of some property as capital gains in the UK are taxed differently.
isn31c, thanks for the catch
Interesting. THE U.S. taxes my US and my Hungarian earnings and Hungary taxes both as well. EDITED
And AI lists a couple of countries other than the US, and AI is never wrong (see my list above)
I’m not a fan of this legislation, but I am a fan of the Pittsburgh Steelers. If six Super Bowl trophies puts you on the side of badness, I can live with that, David. ; )
Six! That's it! I'm moving to Pittsburgh!
But first I'm writing my Senator to oppose this bill!
Happy Travels
I hope this does not gain traction. I have dual Canadian/US; my husband has US/Lux; and my kids have all 3...
One would assume that this has zero chance of being passed but I confess the my ability to say things will utter conviction is diminished (especially since I have adopted dual loyalty to both Cleveland and Pittsburgh.)
Happy travels
I have a lot of experience with citizenship legislation and am sure this won’t go anyone. Hundreds of bills are introduced for every one that passes, and this will not. If it did, it would run into constitutional difficulties from the Supreme Court cases in the 1950s that expatriation must be a voluntary choice. Current US law basically ignores dual citizenship. It’s not that there is a “right” to it, there isn’t, but from the US perspective, if you’re a US citizen that governs your rights and responsibilities, and it doesn’t matter in the least what foreign countries may claim. For those who take US citizenship by naturalization, the oath requires rejection of any foreign allegiance, but that isn’t enforced by requiring surrender of foreign passports or anything like that.
@Gundersen
The US has a special treaty with France that differs from many other countries . This applies to to any American living full time in France whether a dual or not.
Case 1 : 100k earned income in either dollars or euros first reported and taxes paid to the US followed by reporting and paying to France with a 23,000euro exoneration on the non-retirement income. So this person ends up being taxed in France on 77k out of the 100k.
Case 2 : $100,000 in US. Half is pension/social security/other targeted retirement funds. Other half is investment or work income. All is reported and taxed in US. Then in France the retirement income is tax-free, but the earned and investment income beyond the 23,000euro exoneration is taxed. Social charges are paid for health, etc in the taxable 27k.
In most countries, US citizens are double-taxed if they live full time in the other countries. I know someone in the Netherlands who is fully taxed in both countries. US citizens pay a heavy price to live elsewhere.
Question for those who hold JD, perhaps an LLM or maybe an SJD.
In the case of Lilibet Diana Mountbatten-Windsor, AKA Princess Lilibet of Sussex, how or who is going to annul her birthright to dual citizenship as per your 14th amendment. Bearing in mind that Prince Henry, Duke of Sussex was not/is not a diplomat, and neither is his wife the Duchess of Sussex?
Seems to me that will have to be adjudicated by the full Supreme Court.
Regards Ron
The 14th Amendment doesn't guarantee her dual citizenship. If she was born in the US, then she has US citizenship.
What this new bill states is that you can't be a dual citizen if you hold US citizenship. She would have to choose between US and UK. But the new law is not denying her US citizenship.
My take....the new "proposed" law won't be passed. Mostly because of the 14th Amendment. To change the 14th Amendmentment, it would require 2/3 vote by both the House and Senate, and then ratification of 3/4 of the states. That's not going to happen.
The USA once did not allow dual citizenship.
Yes, historically, the United States did not recognize dual citizenship and required individuals to choose one nationality. However, U.S. law has evolved, and currently, citizens can hold dual nationality without losing their U.S. citizenship.
also, regarding double taxation for Americans in foreign countries, there is a tax exemption for foreign earned income.
U.S. citizens and residents living abroad may qualify for the Foreign Earned Income Exclusion (FEIE), which allows them to exclude up to $130,000 of foreign earned income from U.S. taxation for the year 2025. To qualify, individuals must meet specific criteria, including having a tax home outside the U.S. and passing either the bona fide residence test or the physical presence test.
Elizabeth and geovagriffith, thanks.
Because the Republic of Texas has no income tax, I can have dual US and Texan citizenship and not worry about it. But I still pay Hungarian tax on my US earnings. But its not much.
As for other dual citizenships. I have gone through the naturalization process with my wife and kids and several employees that I assisted and friends that i assisted. I've been to at least a dozen ceremonies. I finally asked about the question about alegiance to another country and the explintion was they used that instead of citizenship because there are countries where you become a citizen if you want to or not and revoking your citizenship may not be a legally possible thing in those countires. Sort of you dont claim the country, the country claims you. So the wording is intentional in not mentioning citizenships in other countries. Pretty decent of them.
geovagriffith That’s so true. My Mom had to give up her UK citizenship in the 1960’s when she chose to become a US citizen. She said she decided to become a US citizen because she wanted to be able to vote, and she was married and had 2 children so she knew she was sticking around. It was still a difficult thing to renounce her UK citizenship though. I think they changed that later in the 1960’s that people could retain dual citizenship but she never pursued that. I have wondered if I would be able to get dual UK citizenship because she was from there but I never looked into it very much.
It will never pass committee. The Israeli-American lobby will have feelings about this. But it is just one of many efforts out right now to throw mud at immigrants. Efforts that "they" know have no legs, but will stick in people's minds and stoke anti-immigrant feelings.
The extreme right in France tossed that bone into the public arena. The reaction against it was so strong that they buried it.
In 1967 and 1980, there were two Supreme Court rulings that effectively removed the earlier prohibition against dual citizenship. Here’s a summary that I found on the internet:
Afroyim v. Rusk (1967): This landmark case held that U.S. citizens cannot be involuntarily stripped of citizenship. Afroyim, who had voted in an Israeli election, was targeted under a provision of the INA for allegedly relinquishing his U.S. citizenship. The Court ruled that citizenship is a constitutional right under the 14th Amendment, and Congress could not revoke it without the individual’s consent.
Vance v. Terrazas (1980): While reaffirming Afroyim, the Court clarified that the government must prove, by a preponderance of the evidence, that a citizen intended to relinquish U.S. nationality before denaturalization could occur. Dual nationality alone is insufficient grounds to revoke U.S. citizenship.
I received Austrian citizenship a couple years ago under their law that restores citizenship to those persecuted under the Nazi regime and their descendants. I have found this citizenship useful for some travel destinations where Americans must get a visa, but Austrians do not (China, Brazil). I also breeze through passport control in EU countries and don’t need to worry about the Schengen time limits.
AI, so probably wrong
Countries with Strict Prohibitions/Restrictions:
China, India, Japan, Singapore, Kuwait, UAE, Nepal, Qatar, Saudi Arabia, Malaysia, Myanmar, Ethiopia, Laos, Tonga.
Common Scenarios:
Forced renunciation to become a citizen.
Automatic loss of citizenship if another is voluntarily acquired.
Age-based choices (e.g., Singapore, Japan).
Exceptions for special importance (e.g., Saudi Arabia, Azerbaijan).
Countries with Complex Rules:
Austria: Loses citizenship upon acquiring another, unless exempt.
Slovakia: Loses citizenship unless acquired by descent/marriage or with prior declaration.
Ukraine: Has restrictions, often requiring renunciation.
Why Some Countries Ban It:
To ensure undivided loyalty and national unity (China, Singapore).
For legal and administrative clarity (India, via OCI alternative).
Our DIL and granddaughters applied for naturalization in Germany through a recent (2021) program for relatives of holocaust situations such as Renee describes above for her Austrian naturalization. I hope this legislation gets shut down quickly. If affects so many.
Having lived in Germany for a long time, with many friends who have dual citizenship due to one parent being German and the other American, have watched the laws change over time.
Back in the 70s, (if not earlier), if you wanted to keep your American citizenship, you had to go live in the US for 1 year. At some point they dropped that requirement. Boys still had to sign up for the draft at age 18 though. My daughter has dual citizenship because her dad was German. She cannot pass on her American citizenship to her children though, because she has never lived in the US. She would need to live there at least 5 years to be able to pass it on. I doubt this will happen, so it ends with her.
I am happy that Germany now allows Americans to have dual citizenship without having to renounce, though I know enough people who have renounced anyway, due to the horrible tax laws. It just takes forever to become German. People are waiting 2 years due to the major back-log of cases. It is on my list to do, so that I can vote here (finally) and possibly move to other countries if desired, or spend half the year in the US and half the year here.
The legislation in the OP will never pass. They earn too much tax money off of the millions of Americans living overseas.
This bill faces so many hurdles that there's no way it's ever going to come to fruition.
Hi everyone,
Thank you all for the conversation. It's not easy for that to happen without making politics the driving part of the thread when travel and politics cross over so hard.
To that end, I'd like to keep this thread in this state as we head into the weekend. I think the discussion has largely run its course, so I hope you agree with this approach.
