Renunciation rates in Europe: five Swedes renounced citizenship in 2010

Following up on my last post about renunciation rates in Asia, here’s some extracts from EuroStat’s loss of citizenship table, which I ran across recently. (Like last time, all diaspora population figures are taken from the Global Migrant Origins Database, and don’t include ethnic descendants with other citizenships). The EuroStat data is not very good for longitudinal comparisons, since it only shows one or two years, but there’s still some interesting things to be learned from it. One of many instructive cross-sectional comparisons:

United States


  • Diaspora population: 2.2 million
  • Homeland population: 310 million
  • Latest renunciation figure: 1,781 (2011; including former green-card holders)
  • Renunciations per 100k diaspora population: 81
  • Renunciations per 100k homeland population: 0.53

Sweden


  • Diaspora population: 300,000
  • Homeland population: 9.3 million
  • Latest renunciation figure: 5 (2010)
  • Renunciations per 100k diaspora population: 1.66
  • Renunciations per 100k homeland population: 0.032

Greece


  • Diaspora population: 930,000
  • Homeland population: 11 million
  • Latest renunciation figure: 27 (2010)
  • Renunciations per 100k diaspora population: 3.00
  • Renunciations per 100k homeland population: 0.25
Unfortunately, no breakdown was given for their new countries of citizenship.

Ireland


  • Diaspora population: 990,000
  • Homeland population: 4.6 million
  • Latest renunciation figure: 24 (2010)
  • Renunciations per 100k diaspora population: 2.42
  • Renunciations per 100k homeland population: 0.53
  • Popular new citizenships: United States (15)
Ireland has a similar overall renunciation rate to the U.S., but only because their diaspora population is proportionally so much larger, giving them more opportunities for foreign naturalisation. Interestingly, 15 out of the 24 naturalised in the U.S. and went on to formally renounce their Irish citizenship even though they could have kept it.

Renunciations due to prohibitions on dual citizenship

Poland


  • Diaspora population: 2 million
  • Homeland population: 38 million
  • Latest renunciation figure: 354 (2010)
  • Renunciations per 100k diaspora population: 17.7
  • Renunciations per 100k homeland population: 0.93
  • Popular new citizenships: Austria (151), Netherlands (73), Denmark (65), Germany (25)
Poland allows dual citizenship, but 314 of their 354 renunciants in 2010 naturalised in countries disallowing dual citizenship. (Edit: as pointed out by commenters, Germany actually allows dual citizenship in many cases). The other 40 were scattered around the globe.

Estonia


  • Diaspora population: 190,000
  • Homeland population: 1.3 million
  • Latest renunciation figure: 122 (2010)
  • Renunciations per 100k diaspora population: 64
  • Renunciations per 100k homeland population: 9.4
  • Popular new citizenships: Russia (121)
Estonia allows dual citizenship, but only for native-born Estonians, not naturalised citizens. Virtually all of the ex-Estonians became citizens of the Russian Federation, which also doesn’t permit dual citizenship except in cases governed by bilateral treaties (for example, the treaty with Tajikistan). My guess is that they were Soviet-era immigrants returning to their hometowns for a cheaper retirement. Basically a sui generis case.

Croatia


  • Diaspora population: 610,000
  • Homeland population: 4.3 million
  • Latest renunciation figure: 1,231 (2010)
  • Renunciations per 100k diaspora population: 200
  • Renunciations per 100k homeland population: 29
  • Popular new citizenships: Austria (443), Germany (686), Slovenia (54)
Croatia allows dual citizenship, but the Croat diaspora is heavily concentrated in countries which do not permit dual citizenship. Austria and Germany do not permit dual citizenship for adults at all; Slovenia does not permit naturalisation applicants to retain their prior citizenship. The remaining 48 ex-Croats were scattered around the globe. Croatia also has a much larger diaspora proportional to their population than the U.S. does.

Lithuania


  • Diaspora population: 320,000
  • Homeland population: 3.2 million
  • Latest renunciation figure: 580 (2010)
  • Renunciations per 100k diaspora population: 181
  • Renunciations per 100k homeland population: 18
  • Popular new citizenships: Russia (289), Germany (44), Sweden (44), Belarus (41), United States (26), Ukraine (23), Norway (19)
Lithuania does not do a very good job at keeping track of their diaspora; they listed 61 as having acquired “unknown nationality”. I believe that Lithuania does not allow dual citizenship in general.

Netherlands


  • Diaspora population: 790,000
  • Homeland population: 16 million
  • Latest renunciation figure: 361 (2010)
  • Renunciations per 100k diaspora population: 46
  • Renunciations per 100k homeland population: 2.26
  • Popular new citizenships: Turkey (178), Morocco (63), Bosnia and Herzegovina (29)
Guessing by the countries of new citizenship, the vast majority of Dutch renunciants are immigrants returning to their countries of origin. Only 5 ex-subjects of Queen Beatrix became Americans.

Renunciants in some countries retain significant rights

Denmark

  • Diaspora population: 240,000
  • Homeland population: 5.6 million
  • Latest renunciation figure: 417 (2010)
  • Renunciations per 100k diaspora population: 174
  • Renunciations per 100k homeland population: 7.45
  • Popular new citizenships: Sweden (157), Norway (45), Ethiopia (35), China (23), Afghanistan (18), Vietnam (15)
Denmark’s relatively high renunciation rate (comparable to that of Taiwan) can be explained by two factors. The first is the fact that they disallow dual citizenship. The other is that former Danish citizens can easily qualify for residence permits under Section 9d of the Aliens Act. They can then obtain permanent residence permits under the category of “applicants with strong ties to Denmark” after a year in the country. Thus, emigrants can put their minds at ease: they can gain the right to vote in their countries of settlement while still retaining the right to work in Denmark, instead of worrying about banished from the land of their birth like the ex-citizens of the “Land of the Free”.

Though I’m still rather mystified why someone would give up the world’s best passport (at least in terms of travel freedom) for some of the worst, like Ethiopia and Afghanistan. It’s also worth noting: only four ex-Danes became Americans, despite the rather large population of Danes working in the country. U.S. citizenship is not as attractive as those in the Homeland would like to think.

United Kingdom


  • Diaspora population: 4.2 million
  • Homeland population: 62 million
  • Latest renunciation figure: 596 (2010)
  • Renunciations per 100k diaspora population: 14
  • Renunciations per 100k homeland population: 0.96
The UK permits dual citizenship, and also has very generous procedures for resumption of citizenship by former citizens. In general these provisions seem to have been designed to defeat their former colonies’ insistence on single citizenship or on politicians renouncing other citizenships before taking office. Many Britons “renounce” in order to gain citizenship in countries which do not permit dual citizenship, and then turn right around and resume citizenship.

Conclusions

Contrary to what the U.S. media would like us to think, 1,780 renunciants is a surprisingly large number for a first-world country, even one the size of the United States. Normal countries do not attempt to criminalise their overseas citizens’ ordinary daily activities, and thus renunciation of citizenship is generally an extremely rare phenomenon in those countries. As we can see from the European example, the vast majority of renunciations are undertaken the purpose of gaining citizenship in another country which does not permit dual citizenship.

The American diaspora is concentrated in Anglophone countries like Canada, the U.K., Australia, and New Zealand. Renunciation of citizenship is not a requirement for them to naturalise where they live, but they pursue it anyway, even against the threat of being permanently exiled by Congressional demagogues.

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

  1. It’s quite odd that there’s no breakdown of Germany, seeing as it’s a country that allows only one nationality (unless they are in the EU) and they keep pretty good tabs on it’s citizens (i.e. every time you move house here, you have to sign out of your former town and register in your new one.) Additionally there’s a huge diaspora population which the German media is always keen on highlighting and showing off, even. (I think it’s actually quite trendy atm to leave Germany for a life abroad: can count 5 television programs off the top of my head.) So I would imagine there must be a pretty good number of renunciations.
    Also, on that note, there’s a huge population of Turkish citizens here, who have to relinquish their passport, in order to receive a German one. It’s a big deal, and why the German gov’t will prob not be changing the law anytime soon to allow dual. But I guess the Prime minister Erdogan basically has said that any “former” Turks, from Germany, will be issued a passport just the same. So there’s another friendly policy towards it’s ex-pats.
    The Greek one is really intriguing. I would hazard a guess that many of these are boys growing up in foreign country who don’t want to go back for military service.
    It seems easy to get it back in certain cases though.
    http://www.greekembassy.org/embassy/content/en/Article.aspx?office=11&folder=919&article=20574
    Nice post!

  2. I understand most of these renunciations, especially those coming from poorer parts of Europe and naturalising in Germany or Austria like I imagine that the vast majority of the former Polish and Croatian citizens mentioned here have done. Since Poland is in the EU and Croatia is joining next year they will all be able to go back if they wish to as well under the freedom of movement clauses of the EU.

    What I absolutely cannot fathom is why somebody would voluntarily renounce a perfectly good citizenship like the Irish one when it is not required at all. I imagine that some of those 15 people who needlessly renounced their Irish citizenship after obtaining the US one will come to deeply regret that decision in the future. In my book, every citizenship that doesn’t tax you overeases (US or Eritrea) or enforce mandatory conscription (Russia or Singapore) is an asset that should be maintained. I also do not understand why anyone would renounce a Danish or Dutch citizenship for a Turkish, Bosnian or Ethiopian one, even if returning to their home country. Surely all of these countries have lax visa regimes for retirees to return home.

    I have to agree with the post above – Why would you turn in one of the best passports in the world, one that you probably worked and struggled to receive after a decade or more, for ones that are some of the worst in the world in terms of visa free travel and international respect…and also for regimes that are questionably democratic?

    Also, the figures about Morocoo don’t make any sense since they do not recognise the right to renounce their citizenship there. What I mean is that there are lots of Moroccan immigrants in the Netherlands and Belgium who never lost their original citizenship when taking their new EU ones (since they couldn’t legally renounce them), so those people naturalising in Morocco must be spouses of Moroccan citizens I imagine.

    In all, I found this to be a depressing read that so many people would abandon their citizenship when they have no need to do so. I would also like to know where Greeks are renouncing their citizenship? Most of them seem to be moving to the UK, other EU countries or Australia, almost all of which permit dual citizenship.

  3. Sorry for the long post…This just hit a bit closer to home than reading statistics about US citizenship renunciations (which from my perspective is a foreign country).

  4. In Brazil people who descendants of Germans have dual citizenship. Brazilians who married Germans too.

  5. Maybe Germany figures that it is doing former Americans a favor by making them give up their US citizenship.

  6. Eric, remember the “real” renunciation statistics are really “1,700 Covered Expatriates” and not the TOTAL number of people who have renounced. There are countless people who have commented here and on other sites that they were not included in the lists.

    Don, yeah, I kind of think that the people who renounced their “good” citizenship in exchange for the US time-bomb-citizenship are just crazy. They are probably ignorant to the fact of how the US treats people who go overseas.

  7. Very interesting information. It does need to be clarified that at least some of the countries, specifically Germany and Austria, which are listed as not allowing dual citizenship actually do allow it for persons who are born abroad of citizens of those countries and simultaneously acquire citizenship in both countries at birth. These persons are not required to renounce their foreign citizenship in order to retain citizenship in either Germany or Austria. I don’t know about the others.

    A close friend of mine, now retired from Siemens, spent several years in the US in an executive position with a Siemens company. He has a daughter who was born in the US and is very proud of her having a US passport which she uses when they return to the US for a visit. Right now as she is reaching aduthood what is going on taxwise with US citizens living abroad is a matter of concern.

    There is a large colony of Menonites in Brazil that moved there in the 1920 from Russia after the Communist Revolution. They had emigrated from Germany to Russia for religious reasons. Over several generations they have maintained their German citizenship and language, continuing to use it in their church services. I am aware of serveral, one of which I know personally because I worked with him for the same company when he was in Brazil. He now works in Berlin and was able to move from Brazil to Germany using their German passpots. When he accpeted this job offer he explained to me that it would be an easy transition since they all had German passports and spoke German at home.

    It is common for descendants of Germans born in living in South America to maintain valid German passports. Germans can travel to the US without US visas, but if they come to the US as Argentines, Brazilians, Chileans, Peruvians, etc. then they have go through the time consuming process and expense of obtaining US visas, for which a personal interview with a US consul is reuired.

    I also have an Austriaan friend who lives in Austria who was born in the US when his parents lived temporarily in California. He was a teenager when they all returned to Austria. He has both nationalities and faithfully fles US tax returns every year.

    The Baltic republics of Estonia, Latvia and Lithuania all have large populations of Russian speaking citizens whose parents moved theire from the Soviet Union in the years following the forced anexation of these countries by the Soviet Union dring the second world war. The were granted their independence again with the breakup of the Soviet Union. These were atractive places for Soviet citizens to reloacte during those days because all 3 of them were much more highly developed than Russia and other parts of the USSR.

  8. @Don Pomodoro: yeah, the Irish renunciations don’t make any sense to me either. My guess is those 15 or so people probably didn’t do their research and just assumed that because they swore the U.S. oath to “renounce and abjure all allegiance and fidelity to any foreign prince, potentate, state, or sovereignty” that they had to go report loss of citizenship to the Irish consulate.

    @Daniel Kuettel, littlemsami, & Roger: Wow, had no idea about the German dual citizenship thing. Thanks for that. Guess I was wrong. I wonder why all those ex-Poles and ex-Croats renounced anyway then …

    @overseasexile: heh, sorry to be stealing all your post ideas 🙂 Did you ever get the UK data for other years? The Home Office website seems to have some of the statistics online when I search for it, but when I try to actually go to the website it sends me off into a 302 loop

  9. OK, I’m looking at the raw Eurostat data and it doesn’t make sense to me. For example, consider the line “SE,F,DK 67 50 68 : “. (Headers are “citizen,sex,geo\time 2010 2009 2008 2007”). That line suggests that 67 Swedish females gave up their citizenship for Denmark in 2010. That seems at odds with what you’ve reported. And the numbers also seems highly unlikely. For example, the numbers seem (to me) to suggest that around 400 Swedes gave up their citizenship in 2010, not just 5. The description from Eurostat is very unclear.

    Can you clarify?

  10. @overseasexile: I think “GEO” refers to the renounced citizenship and “CITIZEN” refers to the new citizenship. So the line you’re quoting would be ex-Danish citizens who became Swedish citizens. To be honest I had to guess — my logic was that “CITIZEN” includes a lot of countries outside of the EU who I doubt would be reporting their renunciation data to EuroStat, so that must be referring to the new citizenship.

  11. Some other pointers for understanding the data: CC3_07 means the three EU candidates in 2007. I think “STLS” is for “stateless”. HDC/MDC/LDC means “highly/medium/less-developed countries”. The metadata page is (not very) helpful.

  12. Eric, you might be right. By my interpretation, US citizens are flocking to Ireland, Lithuania, and Poland (I seriously doubt that’s correct).

    There’s a full “description” of the data at http://epp.eurostat.ec.europa.eu/cache/ITY_SDDS/EN/migr_acqn_esms.htm, but again, I still can’t tell which is which after reading their description, though they offer a “statistical support” contact page: http://epp.eurostat.ec.europa.eu/portal/page/portal/help/user_support

  13. I found the pre 1997 US renounciation numbers in a GAO report. Here they are:

    1991- 619
    1992- 556
    1993- 697
    1994- 858
    1995 to 1997- 1,903
    1998- 440
    1999- 433
    2000- 522
    2001- 334

    There are some slight inconsistencies in the later years with data we have already seen but I suspect the 1991 to 1997 numbers are fairly accurate.. For some reason they bunched 95 to 97 together.

  14. @overseaexile, you may well be correct on US citizens flocking to Poland. Even before the fall of communism there were a sugnificant number of persons born in Poland who had become US citizens that were returning to their roots in Poland when they retired. With their US retirement pensions and US Social Security benefits they could live like Kings back home in Poland. The second largst “Polish” citiy in the world is Chicago after Warsaw. It is not uncommon there when calling a business to hear “press 1 for English, press 2 for Spanish, press 3 for Polish.” On my last trip to Chicago I stayed at the Sheraton Hotel near O’Hare Airport, which is where the crew members of Lot, the Polish airlines also stay. The hotel desk and coffee shop personnel were fluent in Polish, and lobby announcements were in English and Polish.

  15. @All,

    Thanks for all this interesting information. I will look forward to digesting some of it after today’s commitments.

  16. @Roger: there is also a large German-speaking contingent in Kazkhstan(!) that has a stronger right to citizenship than 4th Generation Turks in Germany.

  17. @Eric…. There you go again, confusing us with data! I joke…

    This does bring to mind the Economist article In praise of a second (or third) passport.

    However, more and more the U.S. Passport may have to be excluded in the multiple passport praise for all the reasons we know too well when living overseas.

  18. @Don, One possibility is pressure from society or family to become a citizen and/or give up old ties. Won’t come up in the stats – might come up in and in-depth study. I have some experience with this. Keeping the old citizenship can be interpreted as an insufficient commitment to the new country. It can make spouses and in-laws nervous about future intentions. Dual citizenship can also be an impediment to political participation in some places. Even where it is legally allowed people do not necessarily want to vote for or give government positions to someone who is a dual. Just a few ideas here….

  19. @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”).

  20. @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.

  21. @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.

  22. @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.

  23. @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.

  24. @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.

  25. @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.

  26. @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.

  27. @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.

  28. @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.

  29. @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.

  30. @ 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.

  31. @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.

  32. 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)?

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

  34. @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.

  35. @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?

  36. 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.

  37. 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).

  38. 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?

  39. 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.

  40. @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.

  41. @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. 🙂

  42. @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.

  43. @victoria, interesting blog. It looks like they have some serious problems (real fubar incidents) deporting US Citizens. I think the hysteria and craziness is going to rip that place apart.

  44. @geeez, Hi there! Isn’t it wild? I had no idea. Guess that U.S. citizenship doesn’t do homelanders much good AT HOME either.

  45. @victoria and @all
    Thank you for the link to Ms Steven’s blog. Indeed very interesting. A huge thanks to all the Brockers. I have learned more about the USA in the past few months than in the past 40 years. Eyes wide open.

  46. @geeez, deporting US citizens? I guess I missed that one. What are the details? Obrigado!

  47. Pingback: 2011, not 1997, had the largest number of reported expatriates | The Isaac Brock Society

  48. @Jefferson — you can read about all the guesswork that went into the data here. Basically it comes from mostly from national censuses between 2000 and 2007; where citizenship data wasn’t available for a given country, they used country-of-birth data instead, and where that wasn’t available, they basically guessed. One likely consequence of all that guesswork was that the vast majority of dual citizens probably were not included (both the ones living in their country of origin who just get counted as local people by their national census, and the ones living in a third country which they entered on their other passport).

    I used the GMOD anyway because even if it undercounts, it probably makes similar kinds of errors between countries, so that the ratios of renunciants to diaspora population are comparable for their magnitude (even if not for their actual number). At some point I will compare the GMOD data to national estimates of emigrants (South Korea and Japan have very good estimates, I’m not sure about other countries) to try to figure out whether the proportion of undercount is actually similar by country.

  49. I bet that the US officially favours the lower 2 million number. Judging by the way that they treat their citizens overseas they are probably embarrassed enough that over 2 million have left the ‘number one country in the world’ for whatever reason 😛

  50. @Don Podormo, All the numbers on how many US citizens are guesstimates, since with US Citiship based taxation many who have US citizenship chose not to reveal it and unlke countries which nurture and go out of their way to maintain ties with their Daspora, fear is the factor that dominates in the lives of US citizens living abroad. One error on your hand calculator total and yoiur FBAR could be classed as intentional mispepresentation of the facts by the IRS and you could face a $500,000 penalty that would wipe you and your out financially.

    The 7 million figure, however, is the latest estimate of none other than the IRS. Weigh this against the 334,861 Form 2111 reports on excuded forieign income submitted by US persons with foreign addresses for tax year 2006 (the latest IRS information available) and you will get a sense of the magnitude of the problem crearted by Cizenship-based taxation.

    Yet unlike several other industrialized countries with re4presentatives in their legislatures directly electred by and representing their overseas citizens, the US has none of that. The websitres of US Congressman and Senators will not even accept email messages from their constituents abroad who do not have US addresses. That gives a pretty good clue as to the total disdain for US citizens with the “traitorous audacity” to live outside of the US which totally permeates the US Congress and the Administration.

    I am even surprised that when a US citizen makes a phone call from abroad to a Washington legislator that they don’t just hang up on them when they learn where the person is calling from. Maybe the next step in Washington will be to use caller ID information to automatically block phone calls from outside of the US. I suspect they have just not realized they can do that and simply route such calls to a redording which says “we’re sorry, this number does not accept calls from telephones outside of the United States.”

  51. @Roger Conklin, sending US Congressman and Senators email is free and makes sense even though one will get the “I won’t talk to you” notice. The problem with calling is that one will have to pay the 1 penny per minute voip fee out of one’s own pocket, causing it to not be worth the effort.

  52. @Roger, It was so nice to read your comment this morning. That is exactly the impression I am getting from my elected representatives – I live abroad therefore I am not worthy of their time and attention. I decided to test this hypothesis recently. I have been sending mail to one of my senators on topics other than FATCA and citizenship-based taxation. As the AARO told me to do I preface every mail with a note that says I live abroad (though I must give a Washington address to send the mail through their system). Now I’m waiting for a reply or even just an acknowledgement. Thus far, I’m still waiting. 🙂

  53. @Victoria, Americans abroad should work better together and document each effort to contact a politician on a web site. This would create visible evidence of our current representation situation. In my view, the system should be changed so that we are treated as if we are the 51st State, or we should vote on all matters related to our embassies, such as electing an ambassador, and finance those embassy maintenance costs that we voted for.

  54. @swisspinoy, Yep, that’s my take on it. We need to get organized. This has been a lot on my mind lately. The fight for recognition is something that many diasporas have gone through. I think it would be very useful to look at their experiences and see what we could use. We are not the first to lack representation in the home country but that is not something that has stopped other diasporas. The fact that we haven’t done this basic task of organization says a lot about Americans abroad. Perhaps it was because before this we lacked a trigger (abusive treatment by either our home or host countries). I think other factors might be: lack of humility (I meet very few Americans abroad in my travels willing to admit that they are emigrants/immigrants), a desire not to be part of a “herd” (someone the other day told me how nice it was to be an American in France because there were so few of us and I replied, “What are you talking about? There are around 100,000 of us here!” He didn’t like that one bit) and a strong aversion to direct confrontation with the U.S. (present company excepted). If you look at the notes and minutes from our diaspora organizations when they visit Washington they are so respectful and polite. Okay that is one method and I respect them and their work. But times they are a’changing and I don’t think they are going to be effective unless there are other diaspora organizations (like Isaac Brock) willing to be a little more aggressive. Some days I want to scream, “This is not a cocktail party at the Embassy, folks.” Homelanders and their reps are doing real damage to us and to our families. We need better data to shove under U.S. politicians noses and to release to the media and we need (in my humble opinion) a more radical approach. Something I would love to kickstart but I’m just not sure I can fit it in with my chemo. 🙂

  55. @Victoria, 20 years ago, it was fun to be a visible American expat. One could condemn and praise America while usually being respected for doing so. Yet, for the past 10 years, it has been safer to be an anonymous/hidden American expat, since we are unsure how strongly we are hated by whom, thanks to America’s foreign policy. Often one may find themselves walking on a very thin line, wanting to be a respected and equally treated local without terminating their relations with America. I feel safer with the fact that I lost my US accent, I’ve socialized in person with Americans abroad about 4 times in 11 years, I’ve criticized some for accusing me of being an American and others for accusing me of not being American, and I live in a small village with another American expat whom I spoke with once, at the US consulate while renewing my passport. So, getting us all together in one voice isn’t an easy task, but when US papers ignore our comments, US politicians delete our comments from their facebook page and block us from posting more while refuse to respond to our emails simply because they seek to drop the foreign earned income exclusion, then we become pressured to either become more local or vocal. I’d say, just do what you can and take it one step at a time.

  56. Bit of a depressing conversation to follow about trying to change the system as I’ve given up – My renunciation appointment is this week.

    I am from Belgium, accidental US citizen and I used to really respect the US when I lived there in the late 1990s for five years, but now sometimes I need to pinch myself to believe that the US of today is the same country. I stopped putting my US nationality on my CV a longtime ago and haven’t told any new contacts that I have made for the past few years that I even have (soon to be had…) US citizenship. I don’t even let anyone besides the border any my bank look at my passport because I’m so embarassed of the birthplace now…I usually claim that the photo is butt ugly! (Passport photos are always ugly though so hopefully people don’t find the excuse too strange). Like Swisspinoy my accent in English has also changed from apparently almost native English sounding to some sort of Belgio-German hybrid.

    Is it sad that my favourite question nowadays is when I am asked at the border with my EU passport whether or not I speak English? It just gives me such a good feeling because it means that they don’t realise that I probably hold US citizenship due to the birthplace 🙂

  57. Every renunciation is a finger jabbed into the eye of a tyranny that tries to disguise itself as freedom. Paradoxically, I think the higher the number of renunciations, the greater the chance for change to occur in the future.

    It is the increase in renunciations that gets attention. It exposes the myth of Americans being free for what it has now become, only a myth.

  58. Patrick – therein lies the problem. They only publish the names of the very wealthy people. If they published the names of everyone, even the small guys, that I believe, would be an eye opener for more than just us! But part of me thinks that they deliberately DO NOT publish everyones’ names because it would be a major contradiction to their belief that *everyone* else wants to move to the US.

    Don – yeah, the US is not the same. I’m getting the feeling that this “brainwashing” has been going on for sooo long that even the people who were anti-Bush and anti-war now spew the same stuff about “bombing for peace” and “keeping the US secure through more and more laws and less and less freedom”. They just can’t SEE IT.

    Pinoy – just curious, are you using Pinoy like the millions of other filipinos use it, or is it something else. When I saw your name, I thought, “Filipino naturalized in the US then moved to Switzerland”…I like the get local or get vocal. Sadly, I personally believe interacting with politicians is a waste of time. That’s one reason why I’ve never voted. I can’t recall a single US Politician that has actually *KEPT* his/her word after Clinton. I was perfectly happy being a US Citizen abroad till I discovered this FATCA. That’s when I said “Enough is enough”. I’m just waiting for my citizenship application to go further along because travelling as a stateless person is more expensive and a waste of time to get the visas, should I need to go to the US.

    Victoria – tell that American to come to Brazil. There are very few of us here. He can feel “special” here. Hehehe.

  59. @geeez, SwissAmi would be more accurate and SwiPinAmi has much potential, but SwissPinoy seems to be the mood of Uncle Sam, so I’ll stick with that for now. Personally, I’d favor SwiPinAmiTogoBrazOz, but that would require a lottery ticket, the black market and lots of tongue twisting. I seem to always vote for people who never get elected.

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