Curtis Poe, a fellow U.S. Person abroad and occasional Isaac Brock Society commenter, has an interesting post over at his blog Overseas Exile comparing renunciation rates in New Zealand and the United States. He wrote to New Zealand’s Department of Internal Affairs to get their data, and he’s looking for renunciation-of-citizenship data from other countries as well. This was as good a kick-in-the-pants as I’m ever going to get to compile and summarise the data that I’ve been bookmarking over the past few months from various Asian countries, so I’ve written it all up below. I’ve also done a bit of my own back-of-the-envelope analysis: the U.S. renunciation rate may look small, but it’s actually rather high compared to other countries which allow dual citizenship. Since we have commenters from all over the world here, hopefully some of you can help Curtis out with data from your own countries as well.
This post is very long (update: getting even longer, now that I added South Korea), so here’s a Table of Contents to help you navigate:
I haven’t been able to find an official source, but according to media reports, 1,200 people become ex-Singaporeans each year. Singapore imposes conscription on all male citizens, and it is not possible to renounce without completing military service. (My guess would be that many of the renunciants are expectant parents who don’t want their children to inherit the conscription burden). Interestingly, a quarter of the renunciants are naturalised Singaporeans; Singapore gets large amounts of immigration from India, Indonesia, mainland China, and Taiwan. Of course, they also get a small number from the U.S., but the Americans in Singapore are generally uninterested in naturalisation
Japan’s loss-of-citizenship statistics (link in Japanese) are divided into two categories: kokuseki ridatsu (国籍離脱) and kokuseki sōshitsu (国籍喪失). These correspond respectively to Article 13 and Article 16 of the Japanese nationality law (see here for an English translation). Sōshitsu covers two cases: Japanese people who were born with dual citizenship, and Japanese who as adults acquire a foreign citizenship in a country permitting dual citizenship. As Japanese law does not permit dual citizenship for adults, the former must renounce the Japanese or foreign citizenship before age 22; the latter must renounce Japanese citizenship within two years of acquiring the foreign citizenship (analogous to a U.S. “relinquishment”). I’m less clear on the scope of ridatsu (perhaps Eido Inoue or other Japanese-speaking commenters can offer their correction), but it seems to be the option used by Japanese people who want to acquire the nationality of another country which also does not allow dual citizenship and requires naturalisation applicants to show proof of having lost their former citizenship — also one of the cases covered by U.S. “renunciation”.
Anyway, here’s the numbers for the last five years, which have held fairly constant until seeing a minor rise in 2011:
- 2007: 767 (159 ridatsu, 608 sōshitsu)
- 2008: 798 (179 ridatsu, 619 sōshitsu)
- 2009: 837 (209 ridatsu, 628 sōshitsu)
- 2010: 763 (180 ridatsu, 583 sōshitsu)
- 2011: 880 (168 ridatsu, 712 sōshitsu)
Here are the South Korean government statistics on gain and loss of nationality. The legal terms for loss of nationality (kwukcek ithal 국적이탈 and kwukcek sangsil 국적상실) are cognate to those used in Japan, and describe roughly similar circumstances. The number of people giving up South Korean citizenship is extremely high. Indeed, South Korea is the only developed country in Asia where the number of people losing nationality exceeds the number of immigrants naturalising. South Korea’s foreign population is not particularly large, but it is growing rapidly: now 1.4 million, or 3% of the national population — more than triple the foreign population fifteen years ago. That includes one of the world’s largest Mongolian diaspora populations. (Seoul is the only place outside of Mongolia itself where I’ve ever eaten in an actual Mongolian restaurant run by Mongolians, as opposed to a Chinese restaurant pretending to be Mongolian).
I’d imagine there are several factors contributing to these numbers which are unique to South Korea: third and fourth-generation Korean descendants in Japan who have married Japanese citizens and whose children end up electing Japanese rather than South Korean nationality upon reaching the age of majority, as well as Southeast Asian women in international marriages who divorce and give up South Korean citizenship as part of the procedure to restore their original citizenship. One factor which South Korea has in common with Taiwan is emigration by non-breadwinning parents who accompany the children to study in English-speaking countries. Many of these families acquire local citizenship; however, unlike Taiwan, South Korea did not allow dual citizenship for adults until 2011. Eventually, though, many of the parents (and their children) may end up returning to South Korea anyway and applying for restoration of nationality — something which is not an option for those of us in the American diaspora who give up our citizenship.
Anyway, the numbers:
- 2002: 24,753 (770 ithal, 23,983 sangsil)
- 2003: 28,457 (826 ithal, 27,631 sangsil)
- 2004: 23,297 (1,407 ithal, 21,890 sangsil)
- 2005: 25,787 (2,941 ithal, 22,846 sangsil)
- 2006: 22,372 (673 ithal, 21,699 sangsil)
- 2007: 23,528 (726 ithal, 22,802 sangsil)
- 2008: 20,439 (276 ithal, 20,163 sangsil)
- 2009: 22,022 (886 ithal, 21,136 sangsil)
- 2010: 22,865 (734 ithal, 22,131 sangsil)
Due to historical reasons, the official nationality of people from Taiwan is “Republic of China”. Taiwan permits “outgoing dual citizenship” — a Republic of China citizen can acquire whatever additional citizenships he wants. However, “incoming dual citizenship” is forbidden — a foreigner naturalising as a Republic of China citizen must renounce all his previous citizenships. Loss-of-nationality statistics for the past 10 years are available here in MS Word format (aaargh), in the table on page 3. Note that the year listed there is the “Republic Year”, meaning you add 1911 to get the Western year. Taiwan imposes conscription on all male citizens. According to the Nationality Law, you cannot renounce citizenship without completing military service, unless you moved overseas before turning 15 or never established household registration in Taiwan.
The numbers have been fairly constant for the past ten years:
- 2000: 763
- 2001: 802
- 2002: 814
- 2003: 869
- 2004: 824
- 2005: 803
- 2006: 792
- 2007: 716
- 2008: 780
- 2009: 844
- 2010: 838
See this old post on my personal blog for the dozens of links to the original data sources (the government does not publish this data in consolidated form). Chinese nationality law formally does not permit dual citizenship, but it has been officially legalised in Hong Kong (see here and here), at least for “outgoing dual citizenship” cases like in Taiwan. There are two categories of loss of Chinese citizenship in Hong Kong: “declaration of change of nationality” (for people who already have a foreign citizenship) and “renunciation of nationality” (for people who are acquiring a foreign citizenship). The Hong Kong Immigration Department has committed to processing 80% of “renunciation” cases within three months, and 100% of “declaration” cases within one day if you show up at their office in person with all required documents. This is a sharp contrast to the U.S. State Department, which took more than a year to process Petros’ relinquishment.
There were almost 2,900 “declarations” in 1997 and 1998, connected to the return of Hong Kong to Chinese rule. However, since then there have only been about 50 to 100 each year. There was a small spike in 2004, presumably related to the threat of Article 23 security legislation. This is actually a surprisingly small rise, given that 10% of the population came out on 1 July 2003 to march against the proposed legislation.
Anyway, the raw numbers:
- 1997: 2,283 (2,281 declarations, 2 renunciations)
- 1998: 606 (583 declarations, 23 renunciations)
- 1999: 159 (67 declarations, 92 renunciations)
- 2000: 137 (54 declarations, 83 renunciations)
- 2001: 174 (60 declarations, 114 renunciations)
- 2002: 139 (72 declarations, 67 renunciations)
- 2003: 145 (49 declarations, 94 renunciations)
- 2004: 213 (108 declarations, 95 renunciations)
- 2005: 123 (49 declarations, 74 renunciations)
- 2006: 155 (64 declarations, 91 renunciations)
- 2007: 146 (52 declarations, 94 renunciations)
- 2008: 159 (65 declarations, 94 renunciations)
- 2009: 170 (94 declarations, 76 renunciations)
- 2010: 186 (119 declarations, 67 renunciations)
These numbers are somewhat high relative to the diaspora population (though not as high as other countries in Asia). But there’s an important piece of contextual information to understand when trying to interpret the data: in Hong Kong, nationality is a totally separate issue from permanent residency, and most civic rights in Hong Kong (voting, welfare, undeportability) flow from the latter rather than the former — to give a U.S. analogy, it’s as if you could “downgrade” (upgrade?) from a U.S. passport to a green card. Ironically, most “declarations” are made by returnees who want to remain in Hong Kong while retaining the right to claim foreign consular protection (for all the good it will do them); people who want to leave Hong Kong simply do so without bothering to make any change at all in their Chinese nationality status — and they mostly emigrate to countries like Canada and Australia which also permit dual citizenship.
Except possibly in the case of Hong Kong, it may be more informative to compare renunciation rates in most countries not to the total size of the home country population, but the size of the population living abroad from which the pool of potential renunciants is drawn. Under U.S. law it is certainly possible to renounce U.S. citizenship without having foreign residency permission, but practically no one does it: the only case I’m aware of is Joel Slater, and he was eventually deported back to the U.S. and re-acquired his citizenship. Other stateless ex-Americans like Mike Gogulski and Thomas Jollie already had residence visas for foreign countries.
It is difficult to get year-by-year statistics for the size of a country’s diaspora population. The only consolidated data, the Global Migrant Origin Database, is based on statistics which are up to a decade old. But since I’ve got no other statistics at the moment, let’s run with that: according to the GMOD, the countries in question have the following number of citizens living abroad (I’ve arbitrarily cut the numbers off at three significant figures):
- Singapore: 279,000
- Taiwan: 524,000
- New Zealand: 528,000
- Hong Kong: 714,000
- Japan: 884,000
- South Korea: 1,490,000
- United States: 2,240,000
- New Zealand: 24 renunciations per year, or 4.5 per 100k diaspora population
- Hong Kong: about 180 renunciations per year:
- That would be 25 renunciations per 100k diaspora population
- But as mentioned, renunciation might be better compared to the total population: 2.5 renunciations per 100k total population
- United States about 1,700 renunciations per year:
- If you accept the GMOD number, that’s 75 per 100k diaspora population
- If you believe the State Department’s more recent number of 6 million Americans abroad, that’s more like 28 per 100k diaspora population
- Japan: about 800 renunciations per year, or 89 per 100k diaspora population
- Taiwan: about 800 renunciations per year, or 152 per 100k diaspora population
- I strongly suspect the GMOD undercounts Taiwan’s diaspora population due to people being counted under the “China” category, but I have no way of proving it
- Singapore: about 1,200 renunciations per year, or 431 per 100k diaspora population
- South Korea: about 25,000 renunciations per year, or 1680 per 100k diaspora population
It’s interesting to note: even if you believe the U.S. renunciation rate is only 28 per 100k population, it’s higher than Hong Kong’s renunciation rate — despite the fact that traditionally, U.S. citizenship has been considered much more attractive than Hong Kong Chinese citizenship.
All of the countries mentioned above have first world standards of living — they’re in the world’s top 30 on a GDP per capita (purchasing power) basis, and have themselves become migration destinations for both skilled and unskilled workers. Emigration from these countries should, for the most part, be driven by choice rather than by economic necessity, and in most cases the pool of renunciants is drawn from among emigrants rather than from among the total national population.
The general pattern here seems to be that countries forbidding dual citizenship have much higher renunciation rates than countries permitting dual citizenship; if you’ve emigrated, you’d like to be able to vote in your country of settlement, and naturalisation is often the only way to secure that right. And of course, countries which impose heavy obligations on their citizens such as military service have higher renunciation rates than countries which do not. It’s not surprising that New Zealand has a renunciation rate which is proportionally much smaller than other countries compared to the size of their diaspora. Of course, keep in mind that comparing renunciation rates to diaspora populations gives you “back-of-the-envelope” numbers that are order-of-magnitude estimates at best. But still, it’s interesting to note that the U.S.’s ranking compared to other countries which allow dual citizenship, and to speculate what might happen in the future.
There’s also an interesting comparison that could be done between naturalisation rates and renunciation rates, but I’ll save that for another time.