Along with the U.S. government-reported number of Americans who lose U.S. citizenship each year, various foreign governments report another number that might make American homelanders uncomfortable: the number of Americans who applied for naturalisation in other countries each year. Not all of them necessarily lose U.S. citizenship, but some certainly do.
The European Union publishes a convenient table regarding acquisition of citizenship by sex, age group and former citizenship. About
seven or eight five or six thousand Americans naturalise in European Union countries each year, mostly the United Kingdom and Ireland. Below, I’ve extracted the statistics relating to Americans acquiring local nationality in European countries from 2006 to 2008. The table is split into countries which allow and disallow dual nationality, based on translations of nationality laws published on LegislationOnline.org (click the country name for a link to the law). For countries which I believe disallow dual nationality, I have listed the specific section of the law which prohibits it. If there are any errors, please inform me in the comments and I will make the needful correction.
|Allow naturalised citizens to retain previous nationality|
|Some naturalised citizens may retain previous nationality, others not|
|Germany (Header “Multiple nationality”)||429||434||595|
|Forbid naturalised citizens to retain previous nationality|
|Austria (Article 20)||28||41||62|
|Cyprus (Article 6)||40||30||65|
|Czech Republic (Article 7(1)(b))||3||1||1|
|Denmark (Article 4A)||45||17||21|
|Estonia (Article 1(2))||0||0||0|
|Latvia (Article 29)||0||0||0|
|Lithuania (Article 12(1)(6))||0||1||0|
|Malta (Article 5)||:||16||44|
|Poland (Article 8(2))||8||24||44|
|Federal Register‘s reports of Americans losing citizenship||276||446||226|
|Total number of naturalisations by Americans in EU countries|
Caveat lector: nationality laws are often in flux. I am not sure if Belgium actually permitted naturalised migrants to retain their previous nationality in 2006 and 2007; plenty of news releases stated that they only began allowing dual nationality as of mid-2008. (Edit: based on DonPomodoro’s confirmation, I’ve put the 2006/2007 Belgium naturalisations into the “Forbidden” category, and the 2008 ones into the “Allowed” category; some of them may have occurred during the period when it was still forbidden, but this way gives the most conservative estimate of Americans who would have had to renounce). Cypriot law allows the government to demand naturalised migrants to renounce their previous citizenship, but I am not sure how this law is applied in practise. Luxembourg only began allowing naturalised migrants to retain their previous nationality beginning in 2009; reports from before that time state that “Acquisition of Luxembourg nationality is conditional on the original nationality being relinquished”.
The Netherlands will soon no longer permit dual nationality, but did permit it during the period covered by the above table. Update: And Spain generally forbids dual nationality for Americans, but seems to allow it for Puerto Ricans (for example, singer Ricky Martin). Thanks to DonPomodoro for the comments!
Germany is another complicated case. Germany normally disallows dual nationality. However, it has a special law allowing people stripped of their nationality by Nazi laws, and their descendants, to resume German nationality without giving up their other nationality. I am not sure whether the statistics on acquisition of nationality include this category. Germany also has a provision to waive the prohibition of dual nationality “in the case of unreasonable conditions for release from the foreign citizenship (including excessively high release fees or an undignified release procedure)”. (Austria has a similar provision). $450 plus an exit tax and a Form 8854 seems excessive and undignified to me, but I’m not sure if any American would-be German has ever successfully argued this.
So with those caveats in mind, this data may be another piece of evidence for the theory that the Federal Register only includes covered expatriates, or otherwise under-reports the number of persons losing U.S. citizenship. The actual number of Americans losing U.S. citizenship in any given year must include those who naturalised in “single-nationality EU countries”. But this is not the only path to loss of U.S. citizenship. Other Americans voluntarily report a recent acquisition of non-U.S. citizenship as a relinquishing act. Still others renounce U.S. citizenship while retaining their birth citizenship. This seems to be the case for many of the Cantonese-style names, which also show up in Hong Kong public records of current professional qualifications (like Law Society memberships or Securities and Futures Commission licenses); these people are likely to have retained Chinese citizenship, not gone off and naturalised in Malta.
Similarly, the post-2008 explosion in renunciations of U.S. citizenship is not matched by a rise in naturalisations in single-citizenship EU countries (Austria, Germany, and Malta showed slight falls in 2009; Denmark did not provide data at all). This suggests that the two issues are unconnected; Americans are renouncing U.S. citizenship for reasons other than their desire to naturalise in countries which refuse to let them continue to be Americans. They are renouncing because the U.S. government refuses to let them continue being Americans and passes laws to
make it impossible to continue living a normal life overseas.
Finally, if you are interested in seeing the statistics going in the “opposite direction”, the Department of Homeland Security publishes yearbooks of immigration statistics; the U.S. naturalisation data tables unfortunately only classify applicants by country of birth, not country of other citizenship. A few countries, especially ex-communist ones such as Bulgaria or Romania, send hundreds of times more naturalisation applicants to the U.S. than they receive from the U.S.; however, at the other extreme, in small and wealthy countries like Belgium and Malta, the numbers are far more closely balanced.