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.
Maybe expatriating expats are seen as a reliable source of badly needed revenue – that is until they run out of us.
Me thinks that in the future the only kind of American to be outside the US is an “ex” one. Kudos to those early adopters who got in before they jacked the rate. I wonder if I can still join the Canadian army for a relinquishment? Seems a lot easier than getting elected to office or committing an act if treason.
@Eric
With respect, I think you’ve made an error when it comes to the fees for former Indian citizens to surrender their passports in the US (technically an Indian citizen has already lost his/her Indian citizenship upon acquiring US citizenship, so it is more a matter of documenting the renunciation by surrendering the no longer valid Indian passport). The $17-$37 fee you have listed seems to only be the fee charged by the private company which contracts with the Indian government to provide this service ($17 for new US citizens; $37 for others surrendering in the US). The Indian government itself charges a fee on top of this. Go to the following website:
http://www.in.ckgs.us/processing-fees.shtml
Then select ‘Renunciation’ followed by ‘Renunciation Naturalized on or after 1st June, 2010’. You will see that the total fee–including both CKGS and Indian government fees–ranges from about $45 to about $195 depending on when the US naturalization occurred. There’s another $20 on top of that if the naturalization occurred in a 3rd country (ie not USA or India) but the passport is being surrendered in the USA.
All this is quite separate from the Overseas Citizenship of India (OCI) process that most former Indian citizens go through as the next step–however OCI isn’t mandatory and a former Indian citizen could simply choose to visit India on a standard visa on a US passport.
Petros: Thank you for bringing up the fact that renunciation has become a “commodity”. Commodities cost money and therefore are “privileges” extended only to those who can pay for them. Rights, on the other hand, are defined by the dictionary as those things “to which one is morally or legally entitled”. I see nothing in this definition to suggest that exercising a “right” should carry a price tag. The 14th Amendment gives me and you and every one of us the *right*, unencumbered by fees and taxation, to renounce our citizenship in the United States. Therefore, the US government’s current regime of renunciation rules, fees and threats of exit taxes is unconstitutional.
@MuzzledNoMore.You are welcome. I haven’t heard the 14th Amendment to support the right to expatriate. To be sure it supports citizenship rights, but not to expatriate. The right to expatriate is firmly grounded, however, in the Declaration of Independence. The Expatriation Act of 1868 uses the wording of the Declaration of Independence to argue for the right of expatriation. http://home.earthlink.net/~walterk1/Patr/US/ExpatriationAct.html
@Petros – As of today yes go out and download the CLN PDF, have a fake embossing stamp made, and type it out yourself.
However what I believe will happen is the US will push the work down to the banks and demand them to verify CLNs by some searchable number or term to verify it.
The only safe way is to have a copy of your dual citizen passport made without a US place of birth together with all the legalities involved. It’s doubtful some 18 year old kid at a bank will give your documents the same scrutiny as at a border crossing.
Data integrity is going to be FATCA’s biggest problem at the front end, however, it allows for back tracking that’s the risk.
My question is how long will banks be allowed to hold FATCA data? In many countries data protection laws make organisations destroy data after 6 years if it’s not necessary to keep. The banks willingly do this because it avoids evidence for potential lawsuits after 6 years.
We’ll see.
Don…….Cut it out with the “We’ll see” stuff! You sound like Robert Wood! ; )
@eric – You seem to have missed the information provided on Italy in your table update. This link from the Ministry of Foreign Affairs will give you the information you need in Section 5. Many Italian embassies provide this link on their websites.
http://www.esteri.it/MAE/EN/Italiani_nel_Mondo/ServiziConsolari/Cittadinanza.htm
For your table, the answers (found in Section 5) are: You cannot renounce by mail. You can renounce in Italy or at an Italian consulate abroad.
Currently, there is no fee for this service based on what is published on the websites of consulates. However, for their popular services such as acquisition of citizenship by descent and marriage fees have just been instituted, Renunciation does not appear to be a service in major demand, nor have been done very much in the past, which is why it appears there is no fee. Many Americans, Australians and Argentinians are now asking for recognition of Italian citizenship, some tracing their line as far back as great-great-great grandfathers and most consulates are overloaded with this work, which is why the fees for citizenship recognition were just introduced on 8 July this year. It is the exact opposite situation to most US consulates. Waiting times for citizenship appointments in many Italian consulates are for appointments one year in the future.
updated again
@Not that Lisa: blaargh, I must have messed up that entry when I rearranged the tables. now it’s back. thanks again.
@Dash: ah, good catch, fixed now
wait, now I messed the Japan entry. thanks & apologies @Tokyo ROse.
@Eric
Did you mean “messed” or missed?
I’m surprised that there are so many countries more countries that allow dual citizenship than don’t. Of course for someone with Japanese citizenship from birth it is easy to naturalise somewhere else and not bother to tell Japan, but for someone naturalising to Japan there is a very clear record of whether they have abandoned their other nationality.
@TokyoRose: I was in a rush to run out the door to dinner when I was last updating the post, and I accidentally deleted the Japan entry =) — just fixed it now.
Of course for someone with Japanese citizenship from birth it is easy to naturalise somewhere else and not bother to tell Japan — exactly. A while ago, I compared the total number of “国籍喪失者” per year recorded by Japan’s Ministry of Justice against the number of Japanese citizens naturalising in the U.S. according to the Department of Homeland Security. The former number was about a third of the latter. (Wasn’t sure whether I should add the number of “離脱者” into that as well, but even then that would only boost it up to about 50% or so).
http://isaacbrocksociety.ca/2013/09/01/how-many-immigrants-renounce-their-prior-citizenships-after-naturalising-in-the-u-s/
@Eric
Thanks for directing me to your earlier article. Very interesting, especially considering the figures from Japan are for all Japanese loss of nationality worldwide and the US figures are of course only for US naturalization. Also, although I’m not positive on this, I think the figures for 国籍喪失者 that you’ve listed are actually born-duals making the”Choice” at age 20-22, since it says those are based on the Family Register Law and the much smaller number for the 国籍離脱者 that you did not include would be the relinquishers based on naturalization to some other country.
Your earlier article also immersed on me the pitfalls of having dual nationality without paying attention to what might be involved, and also keeping informed rather than just allowing a secondary nationality to lay dormant. Right now many naturalising the US, and also those born dual there, and residing in the US do not see any downside to simple retaining their previous nationality, but things can change.
I still wonder how the large number of Japanese citizens residing in Japan with dual US nationality or a dormant green card are going to deal with FATCA. There has been zero media coverage and the banks are being very slow in verifying anything, even for new accounts being opened since July 1.
Another issue is some countries like the UK I believe allow people to reapply for their citizenship after renouncing unlike the sour grapes attitude of the US.
Once you renounce you’re basically branded as a traitor and not allowed back into the fold.
China’s pretty straight forward.
1) You cancel your hukou (residency) – this is free.
2) You submit your application to renounce – this is 200 RMB and wait.
Depending on where you go, it could be same day, or it could be a year if you did things out of order. On average it seems to be about 4 working days if you do it abroad, and then next trip to China, you have to handle the cancellation of the hukou/residency stuff before you can leave. There’s no real time limit imposed nationally, so it all rests with your local public security office, but in most places they have a maximum of about 20 working days before you get the certificate.
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