Between Two Worlds -- A Question of Dual Citizenship

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How many countries recognize dual citizenship?

The U. S. Office of Personnel Management Investigations Service's 2001 publication, "Citizenship Laws of the World"  identified 52 countries that recognize some form of dual citizenship:

Antigua and Barbuda; Australia; Barbados; Belize; Benin; Bulgaria; Burkina Faso (Upper Volta); Canada; Cape Verde; Central African Republic; Chad; Colombia; Costa Rica; Côte d'Ivoire (formerly Ivory Coast); Cyprus; El Salvador; France; Grenada; Hungary; Ireland; Israel; Italy; Jamaica; Jordan; Kenya; Lebanon; Maldives; Mali; Mauritius; Morocco; New Zealand; Nigeria; Paraguay ; Peru ; Portugal; Romania; Russian Federation; St. Kitts and Nevis; St. Lucia; St. Vincent and the Grenadines; Slovak Republic; South Africa; Switzerland; Syria; Togo; Trinidad and Tobago; Tunisia; Turkey; Tuvalu (South Pacific); United Kingdom; Uruguay.

The United States is the 53rd country on the list, according to Victor Chen ("1 Person, 2 Passports," Newsday, Jan. 3, 1999). "These days," wrote Chen, "the State Department allows dual citizenship except in extreme cases, such as serving in the military of a country at war with the United States." Until 1967, however, the State Department revoked the American citizenships of "even U.S.-born citizens who naturalized in another country or voted in foreign elections." The Supreme Court decided in favor of more lenient treatment, and the government now makes no real distinction between dual citizens and other citizens, provided that the "duals" obey the nation's laws. When naturalized United States citizens take the oath renouncing allegiance to any foreign government, they are not surrendering dual citizenship.

It is difficult to fix at 53 the number of countries recognizing dual citizenship. Many nations that do not generally recognize dual citizenship allow certain exceptions. Some other countries did not provide any citizenship information at all in the "Citizenship Laws of the World" document. What can be said is that most governments do not recognize dual citizenship because it sometimes puts an individual in conflict with the laws of both countries.

Mexico departs from "dual citizenship" altogether, distinguishing instead between nationality and citizenship. In most other countries, however, "dual citizenship" and "dual nationality" are the same. "Citizenship Laws of the World"  defined the concept as "the simultaneous possession of two citizenships. It arises because there is no common international law relating to citizenship."

Marriage to a citizen of another country is a common reason for dual citizenship. Children adopted by citizens of another nation are often dual citizens, as are people born in a country that grants citizenship by birth but whose parents are citizens of a nation that grants citizenship by descent.

If a child is born abroad to American parents, the infant may acquire not only U.S. citizenship but also that of the country of birth. By the same token, a child born to foreign parents in the United States may hold both U.S. citizenship and that of the parents.

Not all nations require naturalized citizens to renounce their former citizenship, and some have even signed treaties affirming duality.

"Citizenship Laws of the World" also explained the principle of dual citizenship by default: "A person naturalized elsewhere without the approval of the country of origin might be considered to retain their original citizenship. If the original country is not notified that another citizenship has been acquired, it is possible for both citizenships to be officially documented."

While many countries permit people who reach the age of legal adulthood to choose which citizenship to keep, others require that those born abroad renounce any other citizenship to retain rights as citizens.

Failure to register a birth with a consular office may result in denial of citizenship. Governments may revoke the citizenships of people who become naturalized citizens of other countries, or automatically release them from allegiance. International law prohibits children of foreign diplomats from becoming citizens of the country of birth in which the parents are serving.