at the same time. Among those countries which do not allow dual nationality, various degrees of strictness can be observed, but often the acquisition of another citizenship without first obtaining a formal permission (which may or may not be obtainable) leads to the automatic loss of one’s current citizenship. Therefore, one needs to carefully check the legal situation in the home country with regard to dual citizenship, prior to taking any steps to acquire another citizenship.
The following is an overview of citizenship regulations in selected countries:44
Selected countries which allow dual citizenship
Source: KALIN (2016)
*Generally not allowed; except for persons who obtain two citizenships at the time they were born. The exceptions to this rule are stated in s 28 of the Austrian Citizenship Act; additionally Austria allows dual citizenship if Austrian citizenship is acquired under § 10 (6) of the Austrian Citizenship Act
**Dual citizenship is allowed in numerous circumstances (s 12 of the German Nationality Act) which have recently extended with the amendments of the German Nationality Act of 2014 (ss 25 and 29)
***According to chapter 14, Annex J-Article 6* of 1951 Pakistani Nationality Law and the amendments 1952,1972,1973 and 2000, holding dual citizenship was not permitted. But now the government of Pakistan recognizes and allows its citizens to also hold citizenships of 16 countries, including Australia, Belgium, Canada, France, Iceland, New Zealand, Sweden, Switzerland, the UK, the US, and others
****Only under limited circumstances, cf. http://www.dualcitizenship.com/countries/lithuania.html; https://usa.mfa.lt/usa/en/travel-and-residence/consular-issues/citizenship-of-lithuania
On the other hand, countries which do not allow the acquisition of another citizenship include the following:
Selected countries which prohibit dual citizenship
Source: KALIN (2016)
19Wallerstein (1974) and Zolberg (1981)
20See Ong (1999)
21See for example Torpey (2000), Lloyd (2005), Joppke (2010), Hokema (2002)
22See the Henley & Partners Visa Restrictions Index (HVRI); www.henleyglobal.com/hrvi
23This can happen even to citizens of small and generally neutral countries, as Danish citizens experienced following the publication of Mohammed cartoons in the Jyllands-Posten newspaper in Denmark on 30 September 2005
24The Economist, 19 February 2013 ‘Tourist visas: You’re not welcome’
25For a good discussion of the differences between residence and citizenship statuses, see Joppke (2010)
26See Betten (1998) and chapter 3 in this book
27See Ong (1999)
28For example in St. Kitts and Nevis
29Although some countries, such as the UK and New Zealand, have introduced limits to the passing on of citizenship infinitely through blood line if not also remaining a resident
30See Hokema (2002) and Hansen/Weil (2001) on multiple citizenship
31Some countries do not even allow you to give up your citizenship unless you have another one. For a good discussion of statelessness, see Stiller (2011)
32For example in China, Malaysia, the UAE and many other countries, there are minority groups which are resident there but are prevented from acquiring citizenship of the country they live in
33In some Swiss Cantons for example, you have to pass an “integration” test, which means that you may need to learn some Swiss history and other things deemed useful to qualify for the privilege of applying for Swiss citizenship. In some Asian countries, if you are not of a particular ethnic origin, your chances of ever being granted citizenship are close to zero. In most Muslim countries you need not apply if you are not Muslim
34Ireland, for example
35For an extensive overview see Bauman (2009) and www.henleyglobal.com
36Henley & Partners constantly monitors and evaluates residence and citizenship programs around the world against a number of criteria
37For an in-depth discussion of these options see Part IV
38For example, Bulgaria, Cape Verde, Grenada, Nauru, the Seychelles, most South American countries, and others
39Montenegro, for example, granted citizenship to the controversial former Thai Prime Minister Thaksin Shinawatra on the basis of a mere promise to invest in the country
40Panama, under its retiree residence program
41Tonga and a couple of African countries
42For more information see the website of the Ministry of Interior of Iceland: http://eng.innanrikisraduneyti.is/laws-and-regulations/english/citizenship/nr/27049
43As has been the case in Costa Rica and other Latin American countries for many years
44The information is based on the author’s own interpretation of citizenship legislation in the relevant countries; for a definitive assessment of the legal situation and possible exemptions, it is necessary to seek legal advice from a specialist in the relevant country
3
Giving up US Citizenship or a US Green Card
By Dr. Marshall J. Langer* and Prof. Denis Kleinfeld**
Chapter Summary
According to the Treasury Department there was a record number of US residents expatriating in 2015, up
