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Citizenship of multiple countries Each country has different requirements for citizenship, as well as different policies regarding dual citizenship. An Australian study estimated that 4-5 million Australians (up to 25% of the Australian population - by far the largest group at 1.6 million of these, from the UK) had dual citizenship in 2000. An estimated sixty percent of Swiss nationals living abroad in 1998 were dual citizens. Approximately 89 countries in the world officially allow some form of dual or multiple citizenship. In the United States it is estimated that millions of Americans are also citizens of other countries. Although Germany has a very restrictive nationality law, it does allow dual citizenship under certain circumstances and the number of dual-citizens was estimated at 1.2 million in 1994. See German nationality law The Republic of Ireland extends its citizenship laws to Northern Ireland, which is part of the United Kingdom. Therefore, most people born in Northern Ireland who are British citizens just like people born else where in the United Kingdom may If they wish, exercise an entitlement to Irish citizenship by simply applying for an Irish passport. Most people born in Northern Ireland may hold either a British passport or an Irish passport or both British passport and Irish Passports. See Irish nationality law and British nationality law. Sub-national citizenship Supra-national citizenship Issues There are some legal issues about dual citizenship and government services. For example, an American citizen holding another nationality and passport will have difficulty getting a security clearance if that person does not surrender the passport of the other country. In Canada, conversely, federal cabinet ministers often have dual citizenship with France or the United Kingdom and this in the past has not been an issue to their security clearances. One small controversy did arise in 2005 when Michaëlle Jean was appointed the Governor General of Canada, Canada's de-facto head of state. Although Jean no longer holds citizenship in her native Haiti, her marriage to French-born filmmaker Jean-Daniel Lafond allowed her to obtain French citizenship several years before her appointment. A section of the French civil code forbids French citizens from holding government or military positions in other countries and Jean's appointment made her both de facto head of state and commander-in-chief of the Canadian forces. The French embassy released a statement that this law would not be enforced because the Governor General is essentially a ceremonial figurehead. Nevertheless Jean terminated her French citizenship two days before taking up office to avoid controversy. Although being a citizen of more than one country can be helpful as it affords two or more passports, it is prudent to realise that each citizenship carries responsibilities. This may bring about problems in conscription, as well as allegiance to more than one state. A dual citizen is subject to travel restrictions, embargoes and sets of laws issued by multiple governments governing one's behaviour domestically and while travelling abroad. Also, as a drawback peculiar to a few countries such as the U.S., citizens are obligated to pay taxes in both the country of origin and the actual country of residence. However, many countries and territories have contracted treaties or agreements of avoiding double taxation. For example, as of 2005, Hong Kong has already contracted 33 agreements that address double taxation or its avoidance. In extreme cases, such as when the countries of citizenship are at war with each other, a dual citizen's international status can be very complicated. The number of multiple citizens is large and increasing. Millions of people in the world are now citizens of more than one country. The number of multiple citizens is going to increase rapidly as people become ever more mobile, living, marrying and having children in multiple countries over the course of their lives. After 11 September 2001, the security issue was raised of persons with multiple citizenship travelling under different names - having passports under their old and new names from different countries - and using one kind of passport to exit a country, while travelling on another passport in a different name abroad, and not disclosing this travel upon return. Legislation is being prepared in Canada to end this practice, and to identify persons travelling abroad under different names and passports, and identify security threats from such individuals. It brings important personal opportunities and responsibilities. As a citizen of a country, you have the opportunity to live there, go to school, work, get medical care, have children, buy property, and retire. There may be agreements to allow freedom of movement to other countries, as in the European Union. (Although it takes just permanent residency to enjoy some of these benefits.) There may also be responsibilities connected with citizenship, such as potential mandatory military service. Examples Example 1: A person born in Canada to a Canadian citizen and an American citizen would have Canadian citizenship by birth, and may also have US citizenship, depending on certain circumstances (the parents' marital status, date of the child's birth, and whether the US citizen parent has met certain physical presence requirements). If the requirements have been met, then the child would also be a US citizen, and therefore would have dual citizenship. Example 2: A person born to American parents in the United States who moves to the United Kingdom may, after five years of legal residence (or three years if married to a British citizen) become a British citizen, and therefore will hold dual British/US citizenship. Example 3: A child is born in Canada to a British born father and a Japanese born mother. The child is entitled to triple citizenship at birth. Lex sanguinis applies for his British and Japanese citizenships through his blood relationship with his father and mother respectively, and lex soli applies for his Canadian citizenship because of his birth on Canadian soil. However, according to Japanese law, at the age of 21 the child would have to decide whether to retain his Japanese citizenship and if so must renounce his British and Canadian passports (although renunciation of British nationality to a foreign authority is not recognised under British nationality law). Furthermore, lex sanguinis would not apply to his children should they be born outside of the UK. Example 4: A British citizen also holds European Union and Commonwealth of Nations citizenship. In addition, most UK citizens born in Northern Ireland are also entitled to citizenship of the Republic of Ireland. See also | ||||||||||
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