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Multiple citizenship
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Multiple citizenship
Multiple citizenship (or multiple nationality) is a person's legal status in which a person is at the same time recognized by more than one country under its nationality and citizenship law as a national or citizen of that country. There is no international convention that determines the nationality or citizenship status of a person, which is consequently determined exclusively under national laws, which often conflict with each other, thus allowing for multiple citizenship situations to arise.
A person holding multiple citizenship is, generally, entitled to the rights of citizenship in each country whose citizenship they are holding (such as right to a passport, right to enter the country, right to work, right to own property, right to vote, etc.) but may also be subject to obligations of citizenship (such as a potential obligation for national service, becoming subject to taxation on worldwide income, etc.).
Some countries do not permit dual citizenship or only do in certain cases (e.g., inheriting multiple nationalities at birth). This may be by requiring an applicant for naturalization to renounce all existing citizenship, or by withdrawing its citizenship from someone who voluntarily acquires another citizenship. Some countries permit a renunciation of citizenship, while others do not. Some countries permit a general dual citizenship while others permit dual citizenship but only of a limited number of countries.
A country that allows dual citizenship may still not recognize the other citizenship of its nationals within its own territory (e.g., in relation to entry into the country, national service, duty to vote, etc.). Similarly, it may not permit consular access by another country for a person who is also its national. Some countries prohibit dual citizenship holders from serving in their armed forces or on police forces or holding certain public offices.
Up until the late 19th century, nations often decided whom they claimed as their citizens or subjects and did not recognize any other nationalities they held. Many states did not recognize the right of their citizens to renounce their citizenship without permission because of policies that originated with the feudal theory of perpetual allegiance to the sovereign. This meant that people could hold multiple citizenships, with none of their nations recognizing any other of their citizenships. Until the early modern era, when levels of migration were insignificant, this was not a serious issue. However, when non-trivial levels of migration began, this state of affairs sometimes led to international incidents, with countries of origin refusing to recognize the new nationalities of natives who had migrated, and, when possible, conscripting natives who had naturalized as citizens of another country into military service. The most notable example was the War of 1812, triggered by British impressment into naval service of US sailors who were alleged to be British subjects.
In the aftermath of the 1867 Fenian Rising, Irish-born naturalized American citizens who had gone to Ireland to participate in the uprising were caught and charged with treason, as the British authorities considered them to be British subjects. This outraged many Irish-Americans, to which the UK responded by pointing out that, just like British law, US law also recognized perpetual allegiance. As a result, Congress passed the Expatriation Act of 1868, which granted Americans the right to freely renounce their US citizenship. The UK followed suit, and starting from 1870 British subjects who naturalized as US citizens lost their British nationality. During this time, diplomatic incidents had also arisen between the US and several other European countries over their tendency to conscript naturalized US citizens visiting their former homelands. In addition, many 19th century European immigrants to the United States eventually returned to their homelands after naturalizing as US citizens and in some cases then attempted to use their US citizenship for diplomatic protection. The US State Department had to decide which US citizens it should protect and which were subjected to local law, resulting in tensions with immigrant communities in the US and European governments. In 1874, President Ulysses S. Grant, in his annual message to Congress, decried the phenomenon of people "claiming the benefit of citizenship, while living in a foreign country, contributing in no manner to the performance of the duties of a citizen of the United States, and without intention at any time to return and undertake those duties, to use the claims to citizenship of the United States simply as a shield from the performance of the obligations of a citizen elsewhere." The US government negotiated agreements with various European states known as the Bancroft Treaties from 1868 to 1937, under which the signatories pledged to treat the voluntary naturalization of a former citizen or national with another sovereign nation as a renunciation of their citizenship.
The theory of perpetual allegiance largely fell out of favor with governments during the late 19th century. With the consensus of the time being that dual citizenship would only lead to diplomatic problems, more governments began prohibiting it and revoking the nationality of citizens holding another nationality. By the mid-20th century, dual nationality was largely prohibited worldwide, although there were exceptions. For example, a series of United States Supreme Court rulings permitted Americans born with citizenship in another country to keep it without losing their US citizenship. Most nations revoked the nationality of their citizens who naturalized in another nation, as well as if they displayed significant evidence of political or social loyalty to another nation such as military service, holding political office, or even participating in elections. In some cases, naturalization was conditional on renunciation of previous citizenship. Many nations attempted to resolve the issue of dual citizenship emanating from people born in their territory but who inherited citizenship under the laws of another nation by requiring such individuals to choose one of their nationalities upon reaching the age of maturity. The US State Department, invoking provisions of the Bancroft treaties, systematically stripped US citizenship from naturalized US citizens who returned to live in their native countries for extended periods of time. However, in the absence of multilateral cooperation regarding dual nationality, enforcement was leaky. Many individuals continued to hold dual nationality by circumstance of birth, including most children born in the US to non-citizen parents.
At the League of Nations Codification Conference, 1930, an attempt was made to codify nationality rules into a universal worldwide treaty, the 1930 Hague Convention, whose chief aims would be to completely abolish both statelessness and dual citizenship. The 1930 Convention on Certain Questions Relating to the Conflict of Nationality Laws proposed laws that would have reduced both but, in the end, were ratified by only 20 nations. One significant development that emerged was the Master Nationality Rule, which provided that "a State may not afford diplomatic protection to one of its nationals against a state whose nationality such person also possesses."
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Multiple citizenship AI simulator
(@Multiple citizenship_simulator)
Multiple citizenship
Multiple citizenship (or multiple nationality) is a person's legal status in which a person is at the same time recognized by more than one country under its nationality and citizenship law as a national or citizen of that country. There is no international convention that determines the nationality or citizenship status of a person, which is consequently determined exclusively under national laws, which often conflict with each other, thus allowing for multiple citizenship situations to arise.
A person holding multiple citizenship is, generally, entitled to the rights of citizenship in each country whose citizenship they are holding (such as right to a passport, right to enter the country, right to work, right to own property, right to vote, etc.) but may also be subject to obligations of citizenship (such as a potential obligation for national service, becoming subject to taxation on worldwide income, etc.).
Some countries do not permit dual citizenship or only do in certain cases (e.g., inheriting multiple nationalities at birth). This may be by requiring an applicant for naturalization to renounce all existing citizenship, or by withdrawing its citizenship from someone who voluntarily acquires another citizenship. Some countries permit a renunciation of citizenship, while others do not. Some countries permit a general dual citizenship while others permit dual citizenship but only of a limited number of countries.
A country that allows dual citizenship may still not recognize the other citizenship of its nationals within its own territory (e.g., in relation to entry into the country, national service, duty to vote, etc.). Similarly, it may not permit consular access by another country for a person who is also its national. Some countries prohibit dual citizenship holders from serving in their armed forces or on police forces or holding certain public offices.
Up until the late 19th century, nations often decided whom they claimed as their citizens or subjects and did not recognize any other nationalities they held. Many states did not recognize the right of their citizens to renounce their citizenship without permission because of policies that originated with the feudal theory of perpetual allegiance to the sovereign. This meant that people could hold multiple citizenships, with none of their nations recognizing any other of their citizenships. Until the early modern era, when levels of migration were insignificant, this was not a serious issue. However, when non-trivial levels of migration began, this state of affairs sometimes led to international incidents, with countries of origin refusing to recognize the new nationalities of natives who had migrated, and, when possible, conscripting natives who had naturalized as citizens of another country into military service. The most notable example was the War of 1812, triggered by British impressment into naval service of US sailors who were alleged to be British subjects.
In the aftermath of the 1867 Fenian Rising, Irish-born naturalized American citizens who had gone to Ireland to participate in the uprising were caught and charged with treason, as the British authorities considered them to be British subjects. This outraged many Irish-Americans, to which the UK responded by pointing out that, just like British law, US law also recognized perpetual allegiance. As a result, Congress passed the Expatriation Act of 1868, which granted Americans the right to freely renounce their US citizenship. The UK followed suit, and starting from 1870 British subjects who naturalized as US citizens lost their British nationality. During this time, diplomatic incidents had also arisen between the US and several other European countries over their tendency to conscript naturalized US citizens visiting their former homelands. In addition, many 19th century European immigrants to the United States eventually returned to their homelands after naturalizing as US citizens and in some cases then attempted to use their US citizenship for diplomatic protection. The US State Department had to decide which US citizens it should protect and which were subjected to local law, resulting in tensions with immigrant communities in the US and European governments. In 1874, President Ulysses S. Grant, in his annual message to Congress, decried the phenomenon of people "claiming the benefit of citizenship, while living in a foreign country, contributing in no manner to the performance of the duties of a citizen of the United States, and without intention at any time to return and undertake those duties, to use the claims to citizenship of the United States simply as a shield from the performance of the obligations of a citizen elsewhere." The US government negotiated agreements with various European states known as the Bancroft Treaties from 1868 to 1937, under which the signatories pledged to treat the voluntary naturalization of a former citizen or national with another sovereign nation as a renunciation of their citizenship.
The theory of perpetual allegiance largely fell out of favor with governments during the late 19th century. With the consensus of the time being that dual citizenship would only lead to diplomatic problems, more governments began prohibiting it and revoking the nationality of citizens holding another nationality. By the mid-20th century, dual nationality was largely prohibited worldwide, although there were exceptions. For example, a series of United States Supreme Court rulings permitted Americans born with citizenship in another country to keep it without losing their US citizenship. Most nations revoked the nationality of their citizens who naturalized in another nation, as well as if they displayed significant evidence of political or social loyalty to another nation such as military service, holding political office, or even participating in elections. In some cases, naturalization was conditional on renunciation of previous citizenship. Many nations attempted to resolve the issue of dual citizenship emanating from people born in their territory but who inherited citizenship under the laws of another nation by requiring such individuals to choose one of their nationalities upon reaching the age of maturity. The US State Department, invoking provisions of the Bancroft treaties, systematically stripped US citizenship from naturalized US citizens who returned to live in their native countries for extended periods of time. However, in the absence of multilateral cooperation regarding dual nationality, enforcement was leaky. Many individuals continued to hold dual nationality by circumstance of birth, including most children born in the US to non-citizen parents.
At the League of Nations Codification Conference, 1930, an attempt was made to codify nationality rules into a universal worldwide treaty, the 1930 Hague Convention, whose chief aims would be to completely abolish both statelessness and dual citizenship. The 1930 Convention on Certain Questions Relating to the Conflict of Nationality Laws proposed laws that would have reduced both but, in the end, were ratified by only 20 nations. One significant development that emerged was the Master Nationality Rule, which provided that "a State may not afford diplomatic protection to one of its nationals against a state whose nationality such person also possesses."
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