Dual citizenship

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Dual citizenship

Postby kirtu » Sun Aug 24, 2014 8:03 pm

Malcolm wrote:
kirtu wrote:
Not so. The US went all in on dual citizenship in the late 70's. Many nations permit dual citizenship like those weaklings the UK, Sweden, France and Switzerland. Ironically Holland and Germany stepped back from dual citizenship during the 70's although Germany now permits some forms of dual citizenship (technically Holland does too again but it's more restricted certainly than Germany or the US). The weak/strong country concept you are advancing is nonsense.



The UK does not permit you to be a dual citizen. They simply don't recognize that you have abandoned your citizenship unless you make a specific declaration to a British authority even if you for example renounced your allegiance to Britain by becoming a US citizen.


That's not what the Her Majesty's Home Office UK Border agency says:

THE LAW IN THE UNITED KINGDOM
1. A person is a dual national if he or she holds more than one nationality or citizenship at the same time. There are normally no restrictions, in United Kingdom law, on British nationals having the citizenship of one or more other countries as well. So you will not need to give up any other nationality if you become British (but see paragraphs 2 - 4 below). Similarly, if you are a British national and you acquire another nationality, you will not normally lose your British nationality. However, special rules apply to British protected persons and certain British subjects (see Note 1).


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Re: Dual citizenship

Postby David N. Snyder » Sun Aug 24, 2014 8:23 pm

The U.S. allows her citizens to have dual-citizenship (if they so choose) with about 60 different nations:

http://www.immihelp.com/citizenship/dua ... tries.html

I knew about Israel because I have some family members that have done that, but didn't know that Iran was allowed.
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Re: Dual citizenship

Postby Mkoll » Sun Aug 24, 2014 9:22 pm

David N. Snyder wrote:The U.S. allows her citizens to have dual-citizenship (if they so choose) with about 60 different nations:

I've heard that a US citizen who leaves still has to pay taxes to the US gov't, no matter where one goes. Is that true?
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Re: Dual citizenship

Postby Malcolm » Sun Aug 24, 2014 9:56 pm

David N. Snyder wrote:The U.S. allows her citizens to have dual-citizenship (if they so choose) with about 60 different nations:

http://www.immihelp.com/citizenship/dua ... tries.html" onclick="window.open(this.href);return false;

I knew about Israel because I have some family members that have done that, but didn't know that Iran was allowed.


sort of, this is what the State Department says:

Also, a person who is automatically granted another nationality does not risk losing U.S. nationality. However, a person who acquires a foreign nationality by applying for it may lose U.S. nationality. In order to lose U.S. nationality, the law requires that the person must apply for the foreign nationality voluntarily, by free choice, and with the intention to give up U.S. nationality.


So in a case where another state grants one citizenship through marriage and so on, one can be a "dual citizen", but the website also stipulates that such a person when traveling must enter and leave using their US passport.

It also says:

The U.S. Government recognizes that dual nationality exists but does not encourage it as a matter of policy because of the problems it may cause.
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Re: Dual citizenship

Postby Malcolm » Sun Aug 24, 2014 9:58 pm

Mkoll wrote:
David N. Snyder wrote:The U.S. allows her citizens to have dual-citizenship (if they so choose) with about 60 different nations:

I've heard that a US citizen who leaves still has to pay taxes to the US gov't, no matter where one goes. Is that true?


Not exactly. They have to pay taxes to the US when their income in that foreign country exceeds a certain amount, which is fairly high.
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Re: Dual citizenship

Postby Malcolm » Sun Aug 24, 2014 10:02 pm

kirtu wrote:
Malcolm wrote:
kirtu wrote:
Not so. The US went all in on dual citizenship in the late 70's. Many nations permit dual citizenship like those weaklings the UK, Sweden, France and Switzerland. Ironically Holland and Germany stepped back from dual citizenship during the 70's although Germany now permits some forms of dual citizenship (technically Holland does too again but it's more restricted certainly than Germany or the US). The weak/strong country concept you are advancing is nonsense.



The UK does not permit you to be a dual citizen. They simply don't recognize that you have abandoned your citizenship unless you make a specific declaration to a British authority even if you for example renounced your allegiance to Britain by becoming a US citizen.


That's not what the Her Majesty's Home Office UK Border agency says:

THE LAW IN THE UNITED KINGDOM
1. A person is a dual national if he or she holds more than one nationality or citizenship at the same time. There are normally no restrictions, in United Kingdom law, on British nationals having the citizenship of one or more other countries as well. So you will not need to give up any other nationality if you become British (but see paragraphs 2 - 4 below). Similarly, if you are a British national and you acquire another nationality, you will not normally lose your British nationality. However, special rules apply to British protected persons and certain British subjects (see Note 1).


Kirt


Note one says:

If you are a British subject, you will lose that status automatically if you acquire any other nationality or citizenship (unless you are a British subject by connection with Ireland). If you are a British protected person, you will lose that status on acquiring any other nationality or citizenship.
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Re: Dual citizenship

Postby Seishin » Sun Aug 24, 2014 10:28 pm

I think that is a bit of confusion with terminology. UK does allow dual nationality (my wife and several friends and family members have dual nationality). A "British Subject" isn't the same as "British citizen" http://en.wikipedia.org/wiki/British_subject

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Re: Dual citizenship

Postby kirtu » Sun Aug 24, 2014 11:17 pm

Mkoll wrote:I've heard that a US citizen who leaves still has to pay taxes to the US gov't, no matter where one goes. Is that true?


It depends. The US has tax treaties/agreements with many nations under which a US citizen can choose to pay US tax or the tax of the country in which they are living. The US makes it very advantageous to a person used to US taxes to pay US income tax as income below a fairly high level is exempt from taxation (for decades it was set at $75,000 and is now definitely higher). However a US citizen must still file a tax form even if they paid income tax in another country.

However some countries will enact double taxation and that is a problem.

Different circumstances are noted in the law and in fact the law can't really cover all these cases. In an unusual case the US isn't going to go after a person for back taxes. For example, many years ago as I was leaving Germany I found out that a friend of mine was a US citizen. He was also a German citizen by birth (both of his parents were German citizens). The US is not going to go after him for back taxes. However he *was* locked out of the German university system and complained about that. I told him that he was a US citizen and would be able to go and get a passport if he could prove his story, the advantage being that at that time he could attend university in the US (although he didn't speak English and I told him he'd have to learn English well). How did my friend acquire US citizenship to begin with? His parents were on vacation in Mexico and were returning home when his mother went into premature labor. My friend was born in an ambulance on the Miami International Airport runway after an emergency landing so he was born on US soil. Being born on US soil is actually the primary means of acquiring US citizenship.

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Re: Dual citizenship

Postby Malcolm » Sun Aug 24, 2014 11:41 pm

Seishin wrote:I think that is a bit of confusion with terminology. UK does allow dual nationality (my wife and several friends and family members have dual nationality). A "British Subject" isn't the same as "British citizen" http://en.wikipedia.org/wiki/British_subject" onclick="window.open(this.href);return false;

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Seishin


Interesting.
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Re: Dual citizenship

Postby Mkoll » Sun Aug 24, 2014 11:44 pm

Malcolm wrote:
Mkoll wrote:
David N. Snyder wrote:The U.S. allows her citizens to have dual-citizenship (if they so choose) with about 60 different nations:

I've heard that a US citizen who leaves still has to pay taxes to the US gov't, no matter where one goes. Is that true?


Not exactly. They have to pay taxes to the US when their income in that foreign country exceeds a certain amount, which is fairly high.

That's right. I remember, now that you mention it, that was what I had heard.
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Re: Dual citizenship

Postby Mkoll » Sun Aug 24, 2014 11:46 pm

kirtu wrote:
Mkoll wrote:I've heard that a US citizen who leaves still has to pay taxes to the US gov't, no matter where one goes. Is that true?


It depends. The US has tax treaties/agreements with many nations under which a US citizen can choose to pay US tax or the tax of the country in which they are living. The US makes it very advantageous to a person used to US taxes to pay US income tax as income below a fairly high level is exempt from taxation (for decades it was set at $75,000 and is now definitely higher). However a US citizen must still file a tax form even if they paid income tax in another country.

However some countries will enact double taxation and that is a problem.

Different circumstances are noted in the law and in fact the law can't really cover all these cases. In an unusual case the US isn't going to go after a person for back taxes. For example, many years ago as I was leaving Germany I found out that a friend of mine was a US citizen. He was also a German citizen by birth (both of his parents were German citizens). The US is not going to go after him for back taxes. However he *was* locked out of the German university system and complained about that. I told him that he was a US citizen and would be able to go and get a passport if he could prove his story, the advantage being that at that time he could attend university in the US (although he didn't speak English and I told him he'd have to learn English well). How did my friend acquire US citizenship to begin with? His parents were on vacation in Mexico and were returning home when his mother went into premature labor. My friend was born in an ambulance on the Miami International Airport runway after an emergency landing so he was born on US soil. Being born on US soil is actually the primary means of acquiring US citizenship.

Kirt

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Re: Dual citizenship

Postby Nemo » Mon Aug 25, 2014 8:00 pm

With the IRS's new disclosure rules many will want to abandon their US dual citizenship. They will not be allowed to until they pay huge penalties.

http://m.theglobeandmail.com/globe-inve ... ice=mobile
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Re: Dual citizenship

Postby Sherab Dorje » Mon Aug 25, 2014 8:52 pm

I hold dual citizenship: New Zealand (where I was born) and Greek (since both my parents are of Greek origin though they hold dual citizenship too). In order to acquire my Greek citizenship I had to do compulsory military service. Fortunately, as a foreign national, I only had to do 6 months instead of 18 months.
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Re: Dual citizenship

Postby Jikan » Mon Aug 25, 2014 10:04 pm

Nemo wrote:With the IRS's new disclosure rules many will want to abandon their US dual citizenship. They will not be allowed to until they pay huge penalties.

http://m.theglobeandmail.com/globe-inve ... ice=mobile" onclick="window.open(this.href);return false;


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Re: Dual citizenship

Postby kirtu » Tue Aug 26, 2014 6:45 am

Nemo wrote:With the IRS's new disclosure rules many will want to abandon their US dual citizenship. They will not be allowed to until they pay huge penalties.

http://m.theglobeandmail.com/globe-inve ... ice=mobile" onclick="window.open(this.href);return false;


It's unlikely that the IRS will actually go after Joe and people like him. The changes in the law are, however, ominous. This can cause people to have to close accounts outside the US as banks will have a burdensome restriction. Additionally the IRS *WILL* demand that US citizens prove that they paid taxes on their income before moving it offshore. How they will handle expatriates is another matter they have thus really not thought out. But the law is intended to ferret out people who are really avoiding taxation. Dual citizens in the past were not subject to this because, depending on the situation, they could decide to pay taxes in their other country or country of residence. These new laws will result in problems but the US will have to modify their stance eventually.

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