70 thoughts on “Renunciation rates in Europe: five Swedes renounced citizenship in 2010”

1. @A Gentleman’s Rapier: yeah, Stalin dumped representatives of pretty much all of the USSR’s minority ethnicities in Central Asia in the years leading up to WWII, to keep them well away from the front lines — Germans, Greeks, Volga Tatars, Poles, et cetera. After the USSR fell, most of the descendants who could get their hands on foreign passports emigrated.

   I used to work with a guy in Seoul whose grandpa got caught up in all that: the grandpa was born in what’s now North Korea, came to Vladivostok as a baby in the 1910s, and got deported to Kazakhstan in 1937; his dad moved to Moscow in the 60s; and my colleague himself came to South Korea for his postgrad degree and ended up finding a job and sticking around afterwards.

   (It’s harder for the Koreans to do that, since they’re not automatically entitled to passports, unlike the Germans. One good paper on this topic: “Transborder Membership Politics in Germany and Korea”).

2. @Victoria, I don’t believe that having dual citizeship in this day and age is really a handicap to political success. Mitt Romney, for example was born to a US citizen father George, who was born in Mexico to US parents and therefore was a dual citizen of Mexico. He had no problem convincing voters of his US loyalty when he became governor of Michigan and later was a candidate in the primaries for president.

   Mitt never mentions it, but under Mexico’s nationality laws, having been born outside of Mexico to a father with Mexican citizenship, he also has Mexican citizenship by birth. He has many cousins in Mexico. With his his father’s birth certificate in hand he could, if he wanted to, walk into a Mexican consulate anywhere in the US and be issued a Mexican passport. Romney’s situation is no different than that of the person born abroad to a US parent who, no matter where he is born or lives, is a US citizen by birth.

   Really just aoujt the only people who have real problems because of their dual citizenship are Americans who live, work or retire outside of the US. And that is because of the unique citizenship-based tax laws of the United States which, wisely for them, no other civilized nation has ever been so stupid as to emulate.

   If I am not mistaken there are several members of the Canadian parlament who are dual citizens of of other countries, but this has not prevented them from running for office or winning elections.

3. @Roger, Michele Bachmann 🙂
   And it’s not considered cool here in France. I have family members who would not vote for a dual for high office. Most of my friends wouldn’t either. Maybe the dual of another EU member state Maybe. Dual of anywhere else… Dicey. Probably depends on the countries involved and perhaps whether the other citizenship is passive (jus soli or jus sanguinis) or active (naturalization) Just my .02.

4. @Victoria,
   I beleve the recent president of France, Sarkozy, was of Hungarian descent. Did he have to go through any sort of a process of renouncing Hungarian citizenship? I confess I am not familiar with Hungarian citizenship laws, specifically as they deal with the transmission ot Hungarian citizenship to children born outside of Hungary.

5. @victoria, I beleive there is a difference in perception depending on how you acquire citizenship in another country. Michelle acquied it voluntarily whereas neither persons born with dual nationality, nor their parents, are looked on with as much oblection. Clearly it was not something Michelle Bachmann needed to do and she did notthing but create problems for herself when she did it voluntarily. She got burned and had no choice but to undo it.

6. @Roger, I think you’re absolutely right and people genuinely feel there is a difference between “inheriting” citizenship and actively seeking it out.
   Sarko is an interesting case. I think it was his mother who was French and his father Hungarian. Not sure if he would qualify for Hungarian citizenship but I’m sure he would never have sought it since that would not have gone over well with his supporters. As long as he doesn’t do something to activate it, I think it’s a non-issue. He’s French. End of story.
   And that I think is the heart of the matter. When I explain to folks here about citizenship by jus soli as practiced in the US which leads to “accidental Americans” they are horrified. All have said that under those circumstances they would not regard a claim by the U.S. as legitimate on any French person and not one in that situation would pay 450 USD to renounce (much less file back tax returns). I think that if the U.S. ever tries this with someone here – someone who was by mere chance born in the U.S. for example – it would be a scandale. I just don’t see how the French government could allow such a thing to happen and still be credible with the French people.
   I should qualify here that the people in France I know best are pretty conservative (I’ve often thought they would be very happy in the Republican party 🙂 So my views are colored by my admittedly small sample.

7. @Roger I think precisely the reason Romney never mentions it is because it could be used against him. I don’t think he views it as an advantage. In a time (post 9/11) when patriotism verging on nationalism is en vogue and popular, bringing out your claim to Mexican citizenship to a population that is turning insular, to non-intervention, and against globalization is not going to win you a majority of votes.

8. @victora, not only has the US “tried it” on Canadians who, for whatever reason happened to have been born in the US of Canadian parents, even those whose mothers about to give birth who crossed the border to get to a hospital in the middle of a billizard within a stone’s throw of their home on the Canadian side, rather than try in vain to reach the nearest Canadia hospital 75 Km distant over a road made impassible by snowbanks. It has been successful. More than a few have been so terrorized that they have paid fines and penalties that, in some cases, have devoured their lifetime savings. And the fact that you were born abroad to a US citizen parent, have never held a US passport, have never in your life stepped on US soil or don’t speak a word of English in no way grants you any dispensation to allow you to escape the long arm of the IRS.

   I agree totally with you the US concept of citizenship-based taxation is a outright violation of the UN’s Decalaration of Universal Human Rights. It was none other than Eleanor Roosevelt, the widow of the President Franklin Delano Roosevelt, who was elected chairman of the commission which drafted this UN Decalaration. And, if I remember correctly, it was ratified unanimously by the nation members of the UN.

   If you have accidental US ciizenship, the only way you are going to escape the long arm of the IRS is to either renounce it or vow to never set foot on US soil. And I totally agree with you that foreign governments have every right, if not an obligation, to protect their citizens against this extraterritorial tax legislation of the US. It is Yankee Imperialism at its worst. What gives the US the right to levy and collect taxes ouside of its own borders?

   But so far no nation, as far as I know, has acted to do this. And even worse than that every nation that has signed a tax treaty with the US has acknowledged the “right” of the US to levy and collect taxes, payable only in US dollars, from US citizens who are bona-fide residents of that country on the income they have earned in that country and anywhere else in the world.

   Until other conntries cease turning a blind eye t this abuse of their own citizens who happen to be dual citizens of the US, the US Congress and the IRS will just keep on tightning the noose around persons who are considered by the US to be US persons, irregardless of where they reside.

   The sooner France or some other country puts it foot down with a firm NO, NON, NEIN, NYET; the better. I feel very stongly this is what has to happen to wake up Washington and start turning this terribly mistaken policy around. Foreign governments can make things happen that indiidual US citizens absolutely cannot.

9. @Victoria, you wrote “I should qualify here that the people in France I know best are pretty conservative (I’ve often thought they would be very happy in the Republican party”

   This is interesting… I think there is a gap between the French conservatives and the republican party here. Republicans are a lot more conservative than the French ones. They seem more aligned with the “Front National”.
   Their ideas seem kind of extreme to me, and I would be more on the conservative side 🙂
   What is really depressing on the political theater in the US is the lack of compromise, which is synonym with lack of leadership. There are good ideas on both sides, I wish both parties would work better together for a better America.

10. @victoria, By the way US citizenship is not something you have to seek. If you meet the conditions of birth which confir US citizenship on you, you ARE a US citizen. You cannot reject or deny it. It is not dependent on your birth abroad having been registered with a US Consulate, or anything else.

11. @WhoaIt’sSteve. He just ignores it, probably because he considers it irrelevant and he would add nothing to the his campaigan. Acidental citizenship and talking about it is no more relevant than his blood type or the color of his eyes. It it is something you are born with and over which you have no control.

    Mexico does not subject its citizens living outside of Mexico to its income tax, or impose any other obligations on Mexicans abroad, such as submitting FATCA or FBAR reports.

    It is only persons with US citizenship that live in a different country that have to concern themselves with things like this, or renounce their US citizenship to escape them.

12. @ Roger Conklin
    That was a very good rant. NO, NON, NEIN, NYET — right on! I was just thinking, thank goodness my Aunt died before she ever got an inkling that her quaint right to dual CND/USA citizenship she often talked about was actually half toxic. She was the only one of 4 children who was by chance born in the USA instead of Canada. Her parents were naturalized Canadians, fresh arrivals from 2 Scandinavian countries. She really did rest in peace because she just didn’t know.

13. Nobody chooses their parents or where they are born. We are ALL ACCIDENTAL AMERICANS!

14. @RogerConklin;
    I am astounded that other countries, like Canada haven’t done this – put their foot down and said NO in public – to the whole extraterritorial claim on their own soil! There is no escaping the fact that when the US asserts a right to enact any and all taxation and banking laws to apply to individuals it claims in other countries – without recourse, it is claiming non-US revenues produced beyond it’s borders, from non-US assets. This seems so fundamental and obvious that I can’t see what the benefit is for Canada and others to acquiese. In addition, Canada is now subsidizing the US directly if it allows the punitive form filling and reporting and penalizing to attach to every means of Canadian government registered savings – because it subverts and significantly undermines the Canadian social and fiscal policy to promote and encourage economic independence in a population that is aging. It subverts attempts to get people to save, for tuition, for retirement, for disability, etc. Why why why would Canada’s government let the US subvert what is obviously a core, highly valued and consistent policy direction? Why let the US SUCK assets out of Canada (and elsewhere) every time tax or a reporting penalty is assessed. As I keep saying – it is not just the million or so duals/accidentals, etc., it is their associated families as well – they sink or swim together as a unit. The Canadian spouse who pays the IRS penalties to save his/her dual children or partner, is paying in Canadian assets directly to the US – a direct transfer from the Canadian economy to them.

    Let’s make a pretend list of all the things that a sample FBAR or other obscure reporting penalty could pay for in our country of permanent residence – wherever that may be:

    Let’s pretend it was ‘only’ a 10,000. fine, or 5-10 years of a cross-border preparer completed ‘simple’ annual 1040 return with an FBAR and FATCA and RRSP and ‘trust’ forms:
    In Canada, or your home country it could have paid for:
    – 1-2 years of post-secondary education for a child, OR for an adult breadwinner who is un/deremployed and needs to retrain to find or keep employment.

    – a cushion for catastrophic life events – unemployment, layoffs, accidents, chronic illness, disability, etc. (resulting in reliance on our home country’s social safety net). Again, any loss of savings is the loss of a cushion for any and all members of the household – not just the one or more shackled with US liability.

    – a downpayment on shelter (house, rent) or car (almost mandatory to get to employment in many communities – not a luxury).

    – how many months of heating and fuel – gas, oil, electricity, etc.?

    – food and clothing for a family for X years?

    – charitable donation to a church, or other local community program (ex. Literacy, food bank, homeless shelter, etc.) – that now isn’t going to happen.

    – X medical expenses, scooter, assistive devices, homecare for the elderly, etc.

    I urge you all to add to the list – of all the constructive things that a sample draconian 10,000 fine (or equivalent in expensive tax form preparation and legal fees spent to establish that we owed ZERO US taxes) could bring to our families and communities and nations – but instead will go to a nation that gives us and our families, communities and country of permanent residence or citizenship – nothing back except fear and threats and punishment. The 10,000. that will NOT benefit us or our communities.

    And the 10,000. figure is on the low side. A lifetime of specialist prepared US tax returns from abroad could be more than 50,000. in a lifetime! What is a million+ ( aprox. US ‘persons’ in Canada) X $50,000. ?

    Write that to our politicians – and point out that having a treaty which allows this – even for permanent residents, allows for the flow of home country revenue – badly needed where we live, to flow outwards to assist a ‘foreign’ nation with its mounting debt. And also point out that there will be absolutely no end to this. They are free to lower reporting and tax thresholds as they see fit, invent new forms and penalties, – and apply them however they want to – with no recourse from us or the countries where we live.

    If we haven’t made much progress getting any workable and easy solution with RRSPs, (over 20 years now?) and Canada fully acknowledges (see the letter from Minister Flaherty to calgary411) that RDSPs, TFSAs, RESPs, and the proposed PRPPs are not and will not be exempted any time soon – and he knows the numbers in Canada who are expected to comply – and thus the million or more who can’t use any of these tax favoured savings – well, why would Canada let the US continue to do this?

    Perhaps in the past, when it wasn’t routinely enforced, there might have been an informal Canadian government complacency about the situation. But now, given the hard evidence of the direction the US has chosen, and the absolute refusal to show any US reasonableness or ethics in the application of the laws (ex. OVD, FATCA, etc.), and the continual invention of further layers upon layers of complex forms and fines – there is no doubt what we can expect in the future. Present behaviour is the best predictor of future behaviour – and there is now several years of evidence. That is very very clear – and it should be clear to our home countries as well – they have more information than we do. So, what is the explanation for why we don’t hear our governments standing up for us in public and just saying NO! It is not enough to state the exceptions for what the CRA will not enforce under certain conditions – I expect the US will just create a way around it.

15. Excellent information, badger. Thanks for a new slant on the discrimination and the cost to us, individually, and collectively for Canada — and other countries.

    Are you going to contribute to the Times article? I have contacted the writer and hope to talk with her. If you are not going to present information to her, could I give this excellent breakdown (if I am contacted)?

16. @ badger
    That is an excellent tactic to take. Don’t drain Canada dry just to quench the thirst of the USA.

17. @Roger,

    re “@victoria, By the way US citizenship is not something you have to seek. If you meet the conditions of birth which confir US citizenship on you, you ARE a US citizen. You cannot reject or deny it. It is not dependent on your birth abroad having been registered with a US Consulate, or anything else.”

    That in itself is a travesty, in that there is absolutely NO CHOICE for Accidental Americans (aren’t we all, as stated?), some more so than others.

18. @calgary411. It turns out tindeed o be a travesty, but it is no different than if you are born within territory of United States. That makes you a US citizen by birth. If you are born in Canada I presume, but please correct me if I am wrong, you are also automatically a Canadian citizen by birth, are you not? The US parent of a child born abroad is encouraged to promptly register the birth with a US consulate, but US citizenship is not conditioned on this being done. Negligence on the part of a parent cannot deprive a child of US citizenship.

    Many months back there was a story in Miami Herald about a lady in Jamaica. Her aged mother, who earlier in her life had lived for a while in the US, had passed away. Going through her mother’s papers she discovered someting her mother had never told her: She discovered her own birth certificate, which revealed that she had been born in the US. She was just a baby in arms when she and her mother returned to Jamaica and never knew she was born abroad. So she took her birth certificate to the US consulate in Kingston and was issued a US passport and now lives in the US.

    Do children born to Canadian parents abroad have to “claim” their Canadian citizenship? Is it forfeited if this is not done within a certain time?

    How does it work with other nationalities?

19. When I was born Canadian citizenship was passed on by the father only. The birth abroad then had to be registered within two years. Many Canadian children lost citizenship because the birth was never registered. The citizenship act was changed to correct this in 1977, and I believe changes have also been made to retroactively restore citizenship to those who had lost it.

20. Hi, Roger.

    I have looked it up — and it is same or similar to the US and probably other nations. The difference, I guess, is in all US citizens, accidental or otherwise, are subjected to citizenship-taxation, the real travesty of no choice.

    http://www.cic.gc.ca/english/citizenship/rules.asp

    This means that children born to Canadian parents in the first generation outside Canada will only be Canadian at birth if:

    one parent was born in Canada, or
    one parent became a Canadian citizen by immigrating to Canada and was later granted citizenship (also called naturalization).

21. and, badger, this

    Let’s make a pretend list of all the things that a sample FBAR or other obscure reporting penalty could pay for in our country of permanent residence – wherever that may be:

    should definitely be in a post of its own — can you do so?

22. Badger –

    I empathize with your emotion, but I also nod to Realpolitik.

    Canada seems idyllic in comparison with the thing that lies to the south, but all nation states tend toward the monstrosities of Revelation 13.

    Canada has said it will not enforce against its own citizens. That leaves the United States little current jurisdiction within Canada on these particular issues, except perhaps in the future through FATCA actions against US-based assets.

    I’d be very surprised to see Canada go one single step further. Just as Canada would not presume to tell North Korea how to legislate on its own citizens.

    That leaves canaries who have flown the coal mine coop to be really careful about (1) possessing any US assets or (2) attempting to see the other side of the Berlin Wall.

    To try put any halo on Canada is a big mistake. The broad current agenda is to roll back those pesky historical accidents like universal health coverage and to continue to privatize the public realm in one-time sell-offs.

    Think about putting more energy into home front struggle and about not expecting to use an intermediary to tilt at inaccessible windbills.

    Resource extraction will occur only among US persons who insist on attempting to maintain personally crippling ties to a cruel and rapacious mother.

23. @Christophe, You’re right there are important differences between the Right in the U.S. and France. Arun at the excellent French blog Arun with a View has a good take on it. Nonetheless I find a lot of similarities on social issues – at least among the people I know here who are staunch Catholics and have a strong association with the military: anti-abortion, for example, pro-national defense, pro-Patrie, for the death penalty and stuff like that. Not one to my knowledge is a member of the Front National – just very conservative people with strong religious convictions. Aside from my family and friends here in France I should mention I live in Versailles which is not only very conservative (Sarkozy won here) but a powerful center for the revival of the Latin Mass in the church. Oddly enough they sometimes send priests trained in the traditional rites to the U.S. – my brother’s church in Sacramento received two French priests from this area for a few years. I was very pleased to meet them when I traveled to the U.S. for my brother’s wedding.

24. @Roger – Agree with you 100%. I loved what you said and I really admire your eloquence. Citizenship is such a strange beast these days – globalization is really ripping holes in the old models. Some folks are proposing alternate models and have some interesting things to say about how citizenship could be redesigned to be a better fit. Jacqueline Steven’s States without Nations: Citizenship for Mortals is a great read. She also blogs here http://stateswithoutnations.blogspot.fr/ Might be interesting to write to her and run some of this by her. In fact, I think I will do that. Good opportunity to tell her how much I admire her work. 🙂

25. @calgary411, thanks, and anyone else – feel free to use whatever you like. I haven’t figured out the process to make the separate post myself.