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  • Tangent: Palm Beach Post on dual citizenship in EU countries

    Posted by Dr. ARUDOU, Debito on July 21st, 2008

    Handbook for Newcomers, Migrants, and Immigrants to Japan\Foreign Residents and Naturalized Citizens Association forming NGO\「ジャパニーズ・オンリー 小樽入浴拒否問題と人種差別」(明石書店)JAPANESE ONLY:  The Otaru Hot Springs Case and Racial Discrimination in Japan

    Hi Blog.  For the last day of the three-day holiday, here’s an interesting diversion on what options dual citizenship provides its citizens.  As well as a quick roundup of what other countries say qualifies for dual at the very bottom.

    Japan, as frequent readers of Debito.org probably know, does not allow dual citizenship.  I consider that to be a big waste, as I know lots of people who would become citizens if only they could preserve both and not have to go through an identity sacrifice.

    Arudou Debito, former American citizen who gave it up to become Japanese.

    ===================================

    With U.S. in slump, dual citizenship in EU countries attracts Americans

    Palm Beach Post, Saturday, June 07, 2008

    http://www.palmbeachpost.com/localnews/content/local_news/epaper/2008/06/07/s1a_dual_citizenship_0608.html

    Courtesy of Matt Dioguardi

    For millions of Europeans who braved the Atlantic Ocean for a glimpse of the Statue of Liberty and dreams of a lavish life, there was little thought of ever emigrating back.

    Yet for a new generation of Americans of European descent, the Old Country is becoming a new country full of promise and opportunity.

    “With an EU passport, I can live and work in 27 countries,” said Suzanne Mulvehill of Lake Worth. “With a U.S. passport, I can live and work in one.”

    Americans can claim citizenship in any of the 27 European countries that are in the EU based on the nationality of their parents, or in some cases, grandparents and great-grandparents. Citizenship in one of those countries allows you to live and work in any EU nation.

    Since the United States doesn’t keep statistics on dual citizens, it’s impossible to know exactly how many people have applied for citizenship in Europe. But it’s estimated that more than 40 million Americans are eligible for dual citizenship, and a growing number of Americans want to try their luck elsewhere.

    “I have to say that over the past few years, calls I never would have received before have been made to the office,” said Sam Levine, an immigration attorney in Palm Beach Gardens. “It’s not like a tidal wave, but it’s certainly more substantial, and it’s remarkable.”

    He’s receiving calls from people like Mulvehill, executive director of the Emotional Institute, a Lake Worth-based company that trains entrepreneurs.

    Mulvehill’s mother was born in Romania, which became a member of the European Union last year.

    She’s obtaining Romanian citizenship, which she estimates will have taken about three years, a ton of paperwork, $750 in fees and a trip to the Romanian consulate in Washington.

    But once she receives the passport, probably early next year, she’ll be able settle anywhere in the EU.

    “I recognized for the first time in my life that being American had limits,” Mulvehill said, “and that if I really wanted to become what I call a global citizen, then I needed to tap into all my resources to expand my ability to serve entrepreneurs not just in Lake Worth, which is one town, and not just in Florida or in America or North America, but on the globe.”

    Globalization is a word on the mind of Lauren Berg, a recent college graduate from Michigan who is obtaining Greek citizenship based on her grandfather. She plans to move to Paris, brush up on her French and engross herself in the European business world.

    “It’s definitely a really good thing to have on your résumé with business going so global,” Berg said. “I probably never would have done it if it wasn’t for the EU, but at the same time I’ve always been extremely proud of my Greek heritage.”

    Dual citizenship once viewed as unpatriotic

    But not everyone is so excited about this increasing trend.

    “I understand the impulse: You can get a better deal over there,” said Stanley Renshon, a professor at the City University of New York and former president of the International Society of Political Psychology. “Whether it’s good for the American national community is quite a different question.”

    Renshon belongs to a faction of immigration experts that believes dual citizenship diminishes the American identity.

    “The devaluation of American citizenship for the sake of comparative advantage strikes me as fairly self-centered,” Renshon said.

    Dual citizenship became a major issue during the War of 1812, when the British military tried recruiting, and in some cases forcing, British-born American citizens to fight on Britain’s side.

    For years, being a dual citizen was seen as unpatriotic, and until 1967 it was possible for the United States to revoke American citizenship for people who voted in foreign elections.

    But in the 1967 Afroyim vs. Rusk decision, Supreme Court justices ruled 5-4 that it was unconstitutional to bar dual citizenship.

    “It was the high point of the 1960s and individual rights,” said Noah Pickus, the associate director of the Kenan Institute for Ethics at Duke University. “So the notion that you could take a citizenship away from somebody would seem to violate the basic notion of individual choice.”

    Today, immigrants who become American citizens have to swear that they renounce their previous citizenship, but it’s more of a symbolic gesture, and Renshon said it’s actually difficult to renounce a citizenship.

    One of the biggest advocates of dual citizenship is Temple University professor and author Peter Spiro, who believes that defining one’s identity by his citizenship is a thing of the past.

    “There are really no harms caused by individuals having additional citizenship these days,” Spiro said. “It’s the wave of the future, because more and more people are going to have it. It’s going to multiply on an exponential basis going forward.”

    And as the value of the euro – the currency shared by 15 EU countries – rises and America’s economy slumps, it’s an attractive alternative for Amber Alfano, a recent University of Florida graduate who is becoming an Italian citizen like her father.

    “I’m doing it as an exit strategy of sorts,” Alfano said. “I like knowing that I have another place to go if things get even worse here, or if I just get tired of running on the American mouse wheel.

    “My dad was actually the one who put a bug in my ear about the whole citizenship thing. He said that Europeans are more interested in the quality of life than the quantity, and that it was a good place to have and raise children because of the way their social systems work. I don’t care much about the child-rearing part, but I would gladly trade in some of my material possessions for a little flat, a scooter and more vacation.”

    The grass might be greener … for now

    Levine, the Palm Beach Gardens immigration attorney, was born in Canada and has received calls from people also interested in obtaining Canadian citizenship. He also understands the European appeal. He said he’s proud to be an American and proud of what the U.S. has accomplished on a global scale in the last century but that there are some advantages to living elsewhere.

    “You have to look at things like how hard people work here and how little vacation time people get here,” Levine said. “A lot of people who live in Europe might not make same amount of money as Americans, but in some senses it’s a kinder, more gentle lifestyle.”

    When Alfano went to fill out her paperwork at the Italian consulate in Coral Gables, she said “the waiting room was full of second- and third-generation Americans (of Italian descent) picking up passports.”

    Pickus said he’s heard stories of parents getting their children European citizenship as an 18th birthday present – “We didn’t get you a car, but we got you an Italian citizenship.”

    Some, like seasonal Vero Beach resident Tony Monaco, who has been trying to get Italian citizenship based on his grandfather, bought property in Italy and learned that taxes would be much lower if he was a citizen.

    For those who are moving for the EU economic boom, Hudson Institute senior fellow John Fonte – one of the nation’s leading immigration experts and critics of dual citizenship – warns that it might not last.

    “I think it’s a short-term phenomenon,” Fonte said. “I don’t think the European economy in the long run will do that well because it’s a heavy socialist welfare state in most of the countries.”

    Mulvehill, the Lake Worth entrepreneur trainer, taught a course at Lynn University and encouraged her students to obtain dual citizenship if they were eligible.

    “Expand your possibilities. If you can get citizenship, why not?” she said. “The world is a bigger place than America. Look at what technology has done, creating a global economy. That, in my opinion, is what has created this phenomenon.”

    Every country has its own process for obtaining citizenship.

    Ireland, Italy and Greece are among the most lenient in terms of letting an individual claim citizenship not just from a parent but from a grandparent or possibly a great-grandparent.

    Even in countries that allow an individual only to claim descent based on a parent, in many cases the new citizen can pass the citizenship on to his child.

    Eric Hammerle, a Vero Beach resident whose father was born in Germany, said it was easy for him and his 16-year-old son Nick to become German citizens.

    They acquired the necessary documents – birth, marriage and death certificates – and took them to the German consulate in Miami.

    “The whole process took about 20 minutes,” Hammerle said. “They read over the documents, came back and said, ‘Congratulations, Germany has two new citizens.’ It was a fee of $85.”

    ENDS
    —————————–
    SIDEBAR

    Dual citizenship criteria

    Ireland: Automatically grants citizenship to the child of an Irish-born citizen. A person can also claim descent based on a grandparent or great-grandparent as long as a grandparent had also claimed descent on or before the date of the person’s birth.

    Italy: For those born after 1948, citizenship is granted if their father or mother was a citizen at the time of the applicant’s birth. Citizenship is also granted under these conditions:

    Father is an American and the paternal grandfather was a citizen at the time of the father’s birth.

    If born after 1948, when the mother is American and the maternal grandfather was an Italian citizen at the time of the mother’s birth.

    Paternal or maternal grandfather was born in America and the paternal great-grandfather was an Italian citizen at the time of the grandparent’s birth.

    United Kingdom: Descent based on a grandparent allowable only in exceptional cases.

    Greece: Native-born parent or grandparent.

    Latvia: Native-born parent.

    Cyprus: Father was a citizen.

    Holland, Finland, Germany and Norway: Applicant must have been born in wedlock with one parent a citizen, or he can claim descent based only on the mother.

    All other European Union countries: A parent was a citizen of the given country. People who can’t claim descent can apply after living in the country for a certain number of years.

    The creation of the European Union and its thriving economy is very appealing for Americans in a global economy.

    SIDEBAR ENDS

    11 Responses to “Tangent: Palm Beach Post on dual citizenship in EU countries”

    1. Big B Says:

      “Americans can claim citizenship in any of the 27 European countries that are in the EU based on the nationality of their parents, or in some cases, grandparents and great-grandparents.”

      Sentences like this are misleading in an article on dual citizenship, as they infer that all E.U. countries allow it. In fact, most E.U. nations either simply do not, or they have extremely stringent criteria for dual citizenship. For example, some stipulate that your “other” citizenship must be of a nation where you legally cannot renounce it (Czech Republic, Denmark). Others mandate that the “other” citizenship must be that of a specific nation (such as former colonies in the case of Spain).

      Some E.U. nations are like Japan and provide for dual citizenship only until adulthood. Some nations even go further. Denmark, if I am reading this right, allows citizens to take up the foreign citizenship of their spouses, but then does not allow the “foreign” spouse to then gain Danish citizenship without renouncing their own. In any case, a summary of the immigration rules concening each E.U. nation can be found here:

      http://eucitizenship.blogspot.com/

    2. AWK Says:

      Most of European countries do not recognize dual citizenship, but…as above link state:

      DUAL POLISH CITIZENSHIP: NOT RECOGNIZED. Poland does not recognize dual citizenship of its citizens. Polish law does not forbid a Polish citizen from becoming the citizen of a foreign state but Polish authorities will only recognize the Polish citizenship.

      What does it mean. This is exactly the same case with United States. As long as you have your own citizenship, you will be treated as citizen of your own country even though you have another one. You can not ask foreign embassy (country you hold citizenship) for help in your country of birth because you still holds its passport.
      In above case, unlike Japan, Poland NEVER take away citizenship from Polish Citizen when Polish obtain foreign one. Constitution do not allow this. One must apply in person to give up. ( United States have very similiar law) It is very, very difficult procedure which may take as long as 2 years.
      Japan on other hand would take away from its citizens immediately, even though they blood is CLEAR Japanese as soon as they find out they have another one.

    3. adamw Says:

      big b ,
      you are confusing 2 separate issues..
      what you say is incorrect-the majority of eu countries do allow
      dual nationality, and do not require people to choose on reaching a certain age .(though in some of these countries this is only in the case that you acquired them at birth)..

      if japan were to adopt similar laws,this would mean that children born in japan to a japanese parent and foreign parent would be able to keep both nationalities without having to choose when they reach a certain age,which seems to me to be common sense-why should people have to choose between their father and their mother?

    4. HO Says:

      AKW, “Japan on other hand would take away from its citizens immediately, even though they blood is CLEAR Japanese as soon as they find out they have another one.”

      I do not see what you are talking about. The procedure to revoke Japanese citizenship is stipulated in Article 16 of Nationality Law which is possible only in much more limited situation than you suggest.

      第十六条 2  法務大臣は、選択の宣言をした日本国民で外国の国籍を失つていないものが自己の志望によりその外国の公務員の職(その国の国籍を有しない者であつても就任することができる職を除く。)に就任した場合において、その就任が日本の国籍を選択した趣旨に著しく反すると認めるときは、その者に対し日本の国籍の喪失の宣告をすることができる。

      “Article 16, paragraph 2.
      If a Japanese national, who has chosen Japanese citizenship over other citizenships, assumes, on his own will, a public office of a foreign county that is limited to the nationals of said foreign country, and if such assumption is grossly incompatible to his choice of Japanese citizenship, Minister of Justice may declare loss of Japanese citizenship for the person.”

      I think people here know quite well. Just say, “I chose Japanese citizenship” to the Government of Japan. They do not enforce loss of other citizenships.

    5. Big B Says:

      “you are confusing 2 separate issues..”

      Am I? I did say that some countries only allowed dual citizenship according to stringent criteria. In any case:

      “if japan were to adopt similar laws,this would mean that children born in japan to a japanese parent and foreign parent would be able to keep both nationalities without having to choose when they reach a certain age”

      Many of the European laws are not as open as you suggest. In many cases you have to be a child of nationals and born abroad to qualify (Austria, Denmark, the Netherlands, Luxembourg and – strangely, if they have fled the country – Slovenia). And in many ‘child of citizen born abroad’ cases dual citizenship is revoked at the age of majority (Denmark, the Netherlands, Finland, Luxembourg and Malta, plus Austrians if you aren’t considered a special case) – that is, the rule is stricter than Japan which allows dual citizenship to the age of majority even if you are born in Japan.

      As for the rest, Belgians have to give up dual citizenship when they reach the age of majority no matter who they are (Same as Japan). Estonia and Latvia flat out do not recognise it along with Lithuania which “generally” doesn’t and provides no information about the cases it might (stricter than Japan). The Czech Republic meanwhile really only accepts it as a technicality. Poland, Latvia and Greece don’t recognise it really, but know deep down they can do nothing about it. But this is not the same as the U.S., as AWK implies. In the U.S. dual citizenship is recognised by law and your dealings with the state (for example entering the U.S., presenting proof of ID) may be handled under your “other” passport. The U.S. does not encourage dual citizenship, but they do recognise it.

      It is pretty clear, AdamW, that there is no consensus (what you call “common sense”) on where the bar for dual citizenship should lie.

    6. adamw Says:

      no,what you said was that the most eu countries dont allow dual nationality or have extremely stringent requirements.
      again not the case .the majority do allow it with no restrictions,
      and of the others some with restrictions.

    7. Big B Says:

      “the majority do allow it with no restrictions”

      Eight out of 25 is not a majority. Even if you count Poland, Latvia and Greece it only comes to 11.

      “and of the others some with restrictions.”

      Yes, and many of those restrictions are similar or harsher than Japan.

      It might come as a shock for you to know that I agree with you, by the way. I think dual citizenship is a good idea. The point I am making is that it is not some sort of natural right. It is widely recognised, even in E.U. treaty law, that citizenship requirements are the prerogative of the particular state.

      The European Convention on Nationality can be read here:
      http://conventions.coe.int/Treaty/en/Treaties/Html/166.htm
      Article 3 dtermines that each state can make up its own rules and article 7 determines that states can revoke the nationality of a dual citizen that has reached the age of majority, which many states do, just like Japan.

      In fact, many E.U. states stress this treaty in their public information on dual nationality. e.g. “It is a fundamental principle of the Danish legislation that dual nationality must be restricted as much as possible…. The Danish principle of avoiding dual nationality as much as possible is in accordance with the 1997 European Convention on Nationality. The Convention makes the contracting states free to decide the issue of dual nationality.”
      http://www.nyidanmark.dk/en-us/citizenship/danish_nationality/dual_nationality.htm

      Attempts to compare Japan to European states in order to urge it to adopt “similar laws” are not only unconvincing because they smack of the old arguments about Japan’s position vis-a-vis the “enlightened” West, they are also unconvincing because many of the assumptions made about dual citizenship in Europe are incorrect.

    8. AWK Says:

      HO

      I know people who had applied for Japanese Citizenship and there was nothing until they got really granted one. After that they had to bring from their embassy proof their revoked their own citizenship. Another case in Japanese Embassies abroad towards Japanese Citizens who have foreign nationality. When Japanese person came to Embassy to renew their Japanese passport, they were asked to show their resident card in order to confirm their status in country they live in. Those who were not able to do this for obvious reason (they had another citizenship) were refused to renew their Japanese Passport. This way GoJ could get people who holds dual citizenship. So, the only choice they had was to CHOOSE which one to give up.
      Regarding Constitution in Japan, it never applies in this country. If it applied we could have more rights and would be able to fight against discrimination. This is just paper here. It does not apply even towards own citizens.

    9. AWK Says:

      HO wrote:

      “…and if such assumption is grossly incompatible to his choice of Japanese citizenship, Minister of Justice may declare loss of Japanese citizenship for the person.”

      You see this is my point, they can take away from you just like that, while in some other countries constitution do not allow it. You must apply in person. They have to check if you paid all debts, have not been convicted, awaiting trial and so on.

    10. HO Says:

      AWK, as I wrote in my comment #4, GoJ may revoke Japanese citizenship in a very limited situation. I wrote the comment so that no one with Japanese citizenship may feel unsafe by believing your untrue comment that GoJ can revoke Japanese citizenship at will.

      The same goes with your untrue comment, “Regarding Constitution in Japan, it never applies in this country.” If a discriminated person reads and believes in your comment, he will just despair rather than stand and fight against discrimination in court. The truth is a lot of discriminated parties have won in Japanese court.

      I am afraid your comments do no good to anyone.

    11. Nigel Says:

      Interesting to see that many European nations base citizenship on bloodline, and not on geography of birth. Japan also bases citizenship on bloodline and not on geography. In contrast, the US, UK and France are all based on geography of birth or bloodline. Either one works.

      Are there any nations in Asia that base citizenship on where one is born? China and Korea are strict bloodline-citizenship states like Japan. Northeast Asian nations are probably not going to adopt any UK/US-style “place of birth” citizenship system if none of their neighbors will agree to such a thing.

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