Update, 27 August 2014: the State Department has officially confirmed the hike in renunciation fees to US$2,350. This post has been edited to reflect the change.
| Countries allowing retention of citizenship after foreign naturalisation | |||||
|---|---|---|---|---|---|
| Country | By mail? | In country? | Fee (local currency) | Fee (US$ at official or current rate) | |
| Australia | Yes | Yes | AU$285 | US$265 | |
| Canada | Yes* | Yes | CA$100 | US$91 | |
| Chile | No | Yes | Free | US$0 | |
| Colombia | Unclear | Yes | N/A | US$80 | |
| Dominica | Yes | Unclear | EC$120 | US$44 | |
| Ghana | (Renunciants in U.S.) | Unclear | Unclear | N/A | US$400 |
| Hong Kong | (1) Declaration | Yes | Yes | HK$145 | US$19 |
| (2) Renunciation | Yes | Yes | HK$575 | US$76 | |
| Ireland | Yes | No? | Free? | US$0 | |
| Israel | No | No | N/A | US$104 | |
| Italy | No | Yes | Free for now? | US$0 | |
| Jamaica | (Renunciants in U.S.) | Yes | No | N/A | US$1,010 |
| Kenya | Unclear | Yes? | Sh 20,000 | US$216 | |
| Lebanon | (Renunciants in U.S.) | Yes | Unclear | N/A | US$350 |
| Nigeria | (Renunciants in U.S.) | Unclear | Unclear | N/A | US$50 |
| New Zealand | Unclear | Yes | NZ$398.60 | US$335 | |
| Pakistan | (Renunciants in U.S.) | Yes | Unclear | N/A | US$150 |
| Peru | Unclear | Unclear | PEN244.60 | US$87 | |
| Sierra Leone | (Renunciants in Germany) | Unclear | Unclear | €500 | US$663 |
| Taiwan | No | Yes | N/A | US$30 | |
| United Kingdom | Yes | Yes | £144 | US$239 | |
| United States | Relinquishment | No | No | Free for now | US$0 |
| Renunciation | No | Not likely | US$2,350 | US$2,350 | |
| Vietnam | No? | No? | VND2.5 mil | US$118 | |
| Average | (Excluding U.S.) | All countries | US$205 | ||
| High-income countries | US$114 | ||||
| Other countries | US$288 | ||||
| Countries disallowing retention of citizenship after foreign naturalisation | |||||
| Country | By mail? | In country? | Fee (local currency) | Fee (US$ at official or current rate) | |
| India | (Renunciants in U.S.) | Yes | Unclear | N/A | US$212 |
| US$20 extra fee for non-U.S. citizen | US$232 | ||||
| Japan | No | Yes | Free | US$0 | |
| Malaysia | (Renunciants in U.S.) | Unclear | No | N/A | US$4 |
| Singapore | (Renunciants in U.S.) | Unclear | Unclear | N/A | US$27 |
| South Korea | (1) “Separation” (이탈) | No | No | US$20 | |
| (2) Loss (상실) | No | Yes | Free | US$0 | |
| Tanzania | Yes? | Unclear | N/A | US$60 | |
| Average | US$57 | ||||
This list as it stands is heavily weighted towards English-, Spanish-, and Chinese-speaking countries. If you’re familiar with fees & requirements in other countries, please leave a comment with a source link and I’ll add it to the table.
Discussion
The U.S. charges unusually high fees for renouncing citizenship — nearly four times the average fee of US$114 in the ten other unscientifically-selected high-income countries & territories in the table which allow you to retain citizenship after naturalising elsewhere. The U.S. doesn’t quite manage to beat the fees charged by Jamaica or Sierra Leone, but that situation is unlikely to last for long — everyone knows the Homelanders can’t stand not being #1, and several commenters report having being told by U.S. consular officials that the fees will be going up.
If this rumoured fee hike does eventually rear its ugly head, it’s reasonable to assume it will cover relinquishments as well as renunciations: the State Department has more documents to search through in the former case (to try to find a reason to refuse, so they can force back-dated relinquishers to become current renunciants instead), and of course they want to offload that cost to the relinquisher.
Update, 27 August 2014: And, less than a week later, Washington has hiked its fees to US$2,350, nearly 2.5x the level in Jamaica and four times that in Sierra Leone, and more than twenty times the average fee charged by other high income countries. Fortunately for people in some countries, my prediction was incorrect and the recent fee hike does not apply to relinquishments, though obviously consulates now an even higher financial incentive to pressure relinquishers to renounce instead, or to pretend they doesn’t know what relinquishment is.
It’s quite interesting to note that middle-income and lower countries on average charge higher fees for renunciation of citizenship than high-income countries. In contrast with first-world countries like Chile and Taiwan which allow people to exercise their human right to change their nationality for free or a nominal cost, the U.S. appears to be joining third-world countries which regard renunciation of citizenship primarily as a last opportunity to extract fees from people who emigrated long ago. (Apparently OVDI fines of 129x tax owed aren’t enough to pay for all those Great Embassy Services.)
And that’s not even mentioning the additional costs incurred by the U.S.’ refusal to accept renunciations by mail — requiring renunciants to travel inter-provincially or even internationally to find a consulate that isn’t totally swamped with appointments and can take your forms within a reasonable timeframe.
Notes
General
In this post, the term “renunciation” is used in its broad meaning of notifying the government of your “old country” that you are no longer a citizen, rather than its U.S. specific meaning of swearing an oath of renunciation under INA § 349(a)(5) (in contrast to “relinquishment” under other subparagraphs of INA § 349(a), which does not require such an oath).
Like the U.S., some other countries have multiple procedures for loss of citizenship. In the table, these have been classified into two general categories (1) and (2), where (1) refers to the procedure used by someone who is already a dual citizen to give up one citizenship, while (2) refers to the procedure used by a person who is about to or has just naturalised in another country and has to give up his original citizenship as a consequence of one country or the other forbidding dual citizenship.
Explanation of certain columns
“In country” is “yes” if a country of citizenship accepts renunciations from people who are physically present in that country, and “no” if that country only accepts renunciations from people who reside abroad. In some of these (e.g. Hong Kong), former citizens retain some immigration rights and can continue to reside automatically or by application for a former citizen’s visa which is granted without income, employment, family relation, or other qualifications; in other countries, former citizens are generally required to depart from the country unless they have some immigration rights arising from their other citizenship (e.g. EU/EEA citizens). At the moment I have not distinguished these separate cases in the table.
“By mail” is yes if a country accepts renunciation forms by mail rather than by showing up in person at a diplomatic post; some countries require the forms to be signed in the presence of a notary public or similar official, but I have still marked those as “yes” (since finding a notary public is a much simpler matter than trekking halfway across the country to a consulate). Dominica allows its renunciation form to be sent by mail, but it’s not clear whether you can pay the fees and buy the required revenue stamps abroad.
The “average” includes only those countries listed in the table; where one country has different fees (either due to multiple loss-of-nationality procedures, like Hong Kong and South Korea, or additional fees charged to people who aren’t citizens of the country where the renunciation is being performed, like India), the higher fee is used to compute the average.
Country notes
Except for India, all notes on fees and procedures come from embassies, consulates, or other government websites, and links are provided in the table; Indian consulates use outside contractors to process renunciation forms, so the links go to the website of that contractor.
Canada allows people in Canada or the U.S. to mail their renunciation forms to Citizenship and Immigration Canada; the webpage tells renunciants in other countries to “submit” their forms to the nearest embassy or consular post, though I’m not clear whether different posts have different policies on whether submissions should be made by mail or in person.
With regards to the fee for making a “declaration of alienage” in Ireland, Irish Nationality and Citizenship Act 1956 § 30 gives the Minister of Justice the power to make regulations on fees for declarations under the Act (with the consent of the Minister of Finance), but I don’t see any mention of a declaration fee in either the the latest regulations or the declaration form itself (which, quite notably, is not an “application” form).
I was initially considering adding a “timeframe” column to the table, but too few governments commit to a time frame within which to process renunciations. However, among those that do, Vietnam states that their processing period is 65 days, Taiwan says two months, and Hong Kong processed 100% of declarations of change of nationality (though not renunciation) made in person at the Immigration Department in 2012 on the same day.
Fascinating, Eric. Thank you.
Good stuff. In Germany one generally loses citizenship automatically unless an application to retain it is filed and approved before naturalising in another country. (There are some exceptions to this, e.g. attaining citizenship of another EU country or Switzerland.). Not sure how you’d want to represent this in your table, perhaps as fees = 0 ?
@notamused: thanks. I think I’ll probably break up the table into two parts, for those countries which let you keep your citizenship when you naturalise elsewhere, and those which don’t. Some of the latter actually do charge seem to charge fees: e.g. India already listed, Singapore (US$27), Korea (IIRC, a nominal fee like 9000 won or so, about US$9), Malaysia (also quite a small fee, though it seems to vary by consulate), etc. Sometimes they claim it’s not really a fee for renouncing but a fee for giving you a certificate.
Among countries which do allow dual citizenship, it looks like Ireland also doesn’t charge any fees? At least they don’t mention it, they just tell you to get the form signed in the presence of a licensed professional who can act as your witness, and then mail it in.
https://www.dfa.ie/passports-citizenship/citizenship/how-do-i-renounce-my-citizenship/
@Eric, the United Kingdom is definately by post and you can also do it in country but then you would have to leave the country when you are no longer a citizen.
@Eric, in Canada they also have an expidited option, you write EXPEDITE or something like that on the envelope and I do not think it costs anymore.
@Eric:
Renunciation fees charged in the Netherlands:
Nigeria: € 100
http://www.nigerianembassy.nl/index_files/Page6118.htm
Ghana: € 400
http://www.ghanaembassy.nl/index.php/consular-section/renunciation-of-ghanaian-citizenship.html
Israel: € 75
http://www.mfa.gov.il/MFA_Graphics/MFA%20Gallery/Consular%20forms/TableFees.pdf
Renunciation fees charged in Germany:
Sierra Leone: € 500
http://www.slembassy-germany.org/?page_id=192
————————————————————————
S. Africa: R300
http://www.home-affairs.gov.za/index.php/tariffs
Renunciation of Israeli Citizenship: $104.
http://mfa.gov.il/MFA/ConsularServices/Pages/Renouncing_Israeli_citizenship.aspx
Parents can renounce a minor’s citizenship. Must be done abroad at Israeli Embassy/Consulate.
I’d also add, they won’t let you do it unless you have another citizenship or are in the process of obtaining one…Many countries refuse to allow you to become stateless.
@George, If i’m not mistaken, UK allows you to suspend your citizenship temporarily as well.
Italy allows you to renounce in-country or abroad. There is no charge, although as of 8 July 2014 there is a new charge of 300 EUR for those seeking Italian citizenship jus sanguinis (by descent). So the charge could come.
Italians are also allowed to reacquire citizenship after having lost it by one year residence in Italy or government/armed forces service. See the attached document for details of acquisition and reacquisition,
http://www.esteri.it/MAE/EN/Italiani_nel_Mondo/ServiziConsolari/Cittadinanza.htm
LOSS OF CITIZENSHIP
An Italian citizens can lose citizenship automatically or formally give it up.
Automatic loss of citizenship:
-any Italian citizen who voluntarily enlists in the armed forces of a foreign government or accepts a government post with a foreign State, despite express prohibition by Italian law;
-any Italian citizen who has served during a state of war with a foreign country, or held a government post or acquired citizenship in that State;
adoptees for which adoption is revoked by fault of their own, on the condition that he/she is in possession of or acquires citizenship in another country.
Formal renunciation of Italian citizenship:
-Adoptees of legal age following revocation of adoption by fault of their own, as long as they are in possession of or acquire citizenship in another country;
-Any Italian citizen resident abroad and that is in possession of, acquires or reacquires citizenship in another country;
-Anyone of legal age who acquired Italian citizenship as a minor following the acquisition or reacquisition of citizenship by one parent, as long as he/she is in possession of citizenship in another country.
-A declaration renouncing citizenship is made before an official of the official statistics office (Anagrafe) of the Italian city of residence or, if residing abroad, before an authorised diplomatic-consular official, and must be accompanied by the following documentation:
a) birth certificate issued by the city of birth and where the birth was registered;
b) certificate of Italian citizenship;
c) documentation of foreign citizenship;
d) documentation of residence abroad, where required.
To be clear, Italy allows dual/multiple citizenship. It allows you to be Italian and have another citizenship if you were born in a country that practices jus soli citizenship. Until 1996, if you naturalized in another country, you automatically lost your Italian citizenship. Since 1996, if you naturalize in another country, you do not automatically lose your Italian citizenship. The Italians are very clear about this and did not retroactively restore citizenship to people who naturalized in other countries before 1996.
@All: thanks for the info. I’m updating the table.
@Innocente: for ZA, I’m not sure what the scope of the R300 fee is (the link says it’s for citizenship certificates), but FWIW the South African High Commission in Australia says they don’t charge a fee for renunciation http://www.sahc.org.au/citizenship/Renunciation.htm
@BenPloni: yes, see Resume your British nationality. Other dual-citizenship countries with similar provisions include Ireland and the Philippines. South Korea, China (including HK), and Taiwan allow it too, but you have to renounce your other citizenship. Still other countries have automatic permanent resident visas for ex-citizens (though you have to wait to qualify for naturalisation.)
Germany doesn’t allow dual citizenship as well. It’s unlikely the Bundesregierung would charge high fees or put stumbling blocks in someone’s way to renounce German citizenship.
So… What is the relative cost of renouncing U.S. citizenship vs. the cost of “renouncing” obligations to the U.S. IRS (as part of expatriation)?
The $450 fee makes renunciation of US citizenship and the obtaining of a CLN a commodity. Once it becomes a commodity it is no longer a fundamental right.
I liken renunciation to other fundamental rights like voting. Imagine if we made ballots a commodity. The rich would win every election, n’est-ce pas?
Let’s say the US State Department decides to increase the renunciation fee to $2000. Let’s say also they add an administrative fee for relinquishment cases–say $200 just to inform them that you are no longer a US citizen. The CLN becomes a highly priced commodity indeed. When are we going to start a black market in CLNs? Faked CLNs seem to me the inevitable outcome of this bullshit. It would be supremely easy to fake them. They are printed on 8×11 standard paper.
I guess Jack Townsend would say it is not honourable to fake a CLN. I don’t know. There seems to be little downside from my point of view. Do the banks have fake CLN detectors, like they do fake currency detectors? Will they even care? Or will they just be relieved that you have one?
Then, when a number of faked CLNs are detected, the US will start printing it on security paper. Then it will be harder to fake.
@Petros,
I don’t know if this is for real or not, but the CLN black market already appears in business: http://bancdelasteroideb612.wordpress.com/2014/01/05/we-used-to-sell-us-citizenship-now-we-sell-non-citizenship-to-us-says-black-marketeer/
@Somewhere, blackmarket CLNs would be adequate for obtaining bank services because I don’t think that determining the authenticity of CLN is an aspect of due diligence–yet. There is the possibility of the over-zealous bank manager, but I think that would be rare.
Perhaps it would be a bit more risky trying to cross the border. US border services might have a better idea who has received authentic exemplars of these precious pieces of paper.
The security paper idea has got me thinking. Soon the US will insist that all CLNs be printed on security paper, and they will insist that legacy CLNs be replaced, in time, with the forgery-proof ones. They will then charge us legacy holders $2000 to replace the old ones. It is a great scheme to help their budget deficit.
To see a CLN, see here.
@BenPloni, While it is defacto suspension, it is dejure resumption.
@Petros, Concerning expatriation as a fundamental right, a reminder to all readers from the Expatriation Act 1868 which remains law;
“Whereas the right of expatriation is a natural and inherent right of all people, indispensable to the enjoyment of the rights of life, liberty, and the pursuit of happiness; ”
AND
“That any declaration, instruc- tion, opinion, order, or decision of any officers of this government which denies, restricts, impairs, or questions the right of expatriation, is hereby declared inconsistent with the fundamental principles of this government.”
I would have to say that ANY road blocks placed in the path of relinquishing/renouncing to include delays or any fee whatsoever is in fact unconstitutional.
@Petros–I ordered and just received a certified a copy of my CLN from DOS passport services Law Enforcement Liasion division. First you have to go to a consulate/embassy ACS and get your request notarized (they waive the usual $50 notarization fee). Then you have to mail a $50 US money order or check to DC with your notarized request. The paralegal I was in touch with in DC via e-mail said I was “fortunate that I have family members who could get me the US money order (after I paypaled the funds to them) — not everyone has US family/friends to get them this.”
The package arrived after 3 months. It contains 2 pages how I could appeal a denial under FOIA/Privacy act (even though it was processed/permitted to be released as I was the first party). The main document is a fancy DOS certificate that looks like a college diploma “signed” by John Kerry saying the records custodian–chief records services division, Ann Murchinson has full faith and credit for her acts as such, which is attached to her 2 page letter of hers signed under penalty of perjury that the attached photocopy of the enclosed CLN is a true copy under and a bunch of other legalese.
@Petros–looks like http://www.flcourts18.org/PDF/Press_Releases/passport_applications.pdf
Great fodder here, Eric. Thank you.
It’s already challenging enough to renounce US citizenship. Any increase in fees added to the cost of filing five years worth of taxes will make it out of reach for many to make a clean break. As the difficulties increase, more people will have to choose between less-favourable options like renouncing without tax compliance, or not renouncing at all and avoiding the US altogether.
The “only rich, unpatriotic Americans renounce US citizenship” myth will become a reality when only the wealthy can afford it or will do anything to free themselves from a nation that treats them like garbage.
Japan (does not allow retention of citizenship after foreign naturalization):
Apply by mail: No (outside Japan must be in person at embassy or consulate
Apply in country: Yes (hundreds of locations throughout Japan)
Fee: 0 (none)
The Japanese info from the Ministry of Justice is here:
http://www.moj.go.jp/ONLINE/NATIONALITY/6-3.html
The only English info I could find is here:
http://www.moj.go.jp/ENGLISH/information/tcon-01.html
I also checked at least half a dozen consulate and embassy websites, and none of them had any info on this in English, which is strange, since there are large numbers of born-dual Japanese nationals living in other countries who do not speak Japanese. Japan prohibits dual citizenship for adults. When someone is born dual, they are supposed to formally abandon one of the nationalities within 2 years after reaching age 20, but many do not bother and just don’t tell the Japanese government about the other nationality. And of course, when a Japanese naturalizes to some other country, they often don’t bother to abandon their Japanese citizenship, even though they are required to so. When an adult naturalizes to Japan, if their nationality cannot be abandoned before naturalization they have 2 years to do it after naturalization.
Incidentally, Japan also charges no fees for naturalization; there is just the cost of getting official copies of all the documents needed (fees for docs from the US were much higher than for those from Japan).
@Eric, very appreciative as always for this type of data and critical analysis presented in a digestible way.
Just part of the US seeking further ways to harvest assets from who live entirely outside the US. If they can’t levy unconstitutional penalties on our local legal savings, they’ll harvest us as we renounce. They levy US extraterritorial taxes and penalties on land that isn’t located in, and doesn’t belong to the US (ex. our Canadian family homes). If via the US version of a Berlin Wall to expatriations we can’t renounce/relinquish, we’re harvested for life and beyond as a taxable person-resource.
The US is making the Harper Conservatives rue the day they voted to implement FATCA in Canada, because the US is set to make FATCA combined with CBT more obviously a nightmare. Small comfort to us, but since the Harperites can’t control what the US does, and the US is stuck on stupid, the Conservatives can expect this disaster to continue to grow in its consequences for ALL Canadian taxpayers, accountholders, citizens, voters and legal residents as well as those claimed involuntarily by the US.
When the US raises the renunciation fee – which is already high, and if they implement a fee for relinquishing, they skewer the Conservative MPs advice to ‘just renounce’. The Conservatives are assisting the US in pushing droves of Canadians to seek remedy by renouncing/relinquishing and exposing people to incredible expenses through the consular fees, travel to consulates/embassy, accounting and legal fees – expenses incurred based on a long ago accident of US birthplace or inherited via a parent’s status. I guess they will announce that they ‘respect’ the US ‘right’ to make its own laws – even those which prevent Canadian citizens and their constituents from divesting themselves of clinging and involuntary US nationality.