My thanks to Cristina Verán, a good friend, who has pointed out a series of brief opinion pieces in the New York Times today, discussing the issue of dual citizenship. Though I do not myself enjoy the privilege of holding multiple citizenships, it is an issue I have very often thought about. And there are so many aspects to it that I scarcely know where to start.
Right: British, French, and German passports against a backdrop of the flag of the European Union. From an eHow article on dual citizenship.
It seems that the chief argument, or ideology, opposing dual citizenship centers on the matter of allegiance and loyalty. How absurd, some argue, that a state should permit its citizens to officially declare allegiances to other states, other nations. This comes out of a strong identification with a state, and loyalty to its government, or at least to its territorial identity and integrity (e.g. loyalty to the Republic of France), as compared to a more culturally or ethnically-based identification (e.g. affinity with the French people). There is certainly a considerable degree of validity to such arguments, whether purely in terms of feeling a sense of unified national Self, i.e. that all one’s fellow citizens indeed consider themselves first and foremost citizens of one’s own country, or in terms of political/military concerns of divided loyalties in times of conflict.
Ron Paul goes so far as to call dual citizenship treason, saying that “when you benefit from the blood spilled by patriots in the past, the least which can be requested of you is undivided allegiance.” The easy and simple counter-argument to such an idea is that we all benefit not only from blood spilled by patriots fighting for the US, but also patriots fighting for other countries, e.g. our respective ancestral homelands. If that’s what it’s really about, that our country (and our countrymen) do so much to allow us to be who we are, and where we are, today, and if it’s about showing our loyalty, our allegiance, in return, then it seems to me all the more reason to maintain citizenships for all the countries we wish to show our allegiance to, all the countries that have done so much to support us.
Yet, putting aside the issue of political allegiances, in terms of personal identity, I think it an absurdity that someone with a complex, multi-national background should have to choose between them. In today’s world, where more and more people are living significant portions of their lives in different countries, where travel and communications and international interactions are so commonplace, it is not unusual for someone to have complex, multi-national backgrounds, being born and/or raised in a country different from that of the citizenship of their parents; having parents whose citizenships are different from one another’s; growing up in multiple different countries, and thus having strong ties to those different places even if one did not (or could not) officially claim citizenship there; or any number of other situations. Mark Krikorian, director of the Center for Immigration Studies, quotes Teddy Roosevelt as calling dual citizenship “a self-evident absurdity,” on the basis of the argument of divided loyalties. Yet, is it not equally absurd for an individual who feels deep in their heart, in the fiber of their being, that they belong to multiple countries, multiple cultures, to be denied the official recognition of that fact, and the formal privileges that should come along with that?
Under Articles 14-16 of the Japanese Nationality Law, anyone born after 1985 to Japanese parents in a foreign country (e.g. the US) must, before the age of 22, choose one citizenship or the other, and cannot keep both. I know plenty of people who were born dual Japanese & US citizens, but have been forced to make this choice (or, people closer to my own age who, fortunately, have not had to make that decision, since they were born before the 1985 law came into effect). How absurd that someone who has grown up in both countries, with the culture of both countries, with both countries an integral part of one’s personal identity, should have to officially give one of these up, and be treated as a foreign national in one of their two homelands. This reminds me of early 17th century Japanese policies implemented when the Spanish & Portuguese were kicked out of Japan, the Dutch restricted to the tiny island of Dejima, and the Japanese forbidden from leaving or returning to Japan. Though I gather this only actually happened in a mere handful of cases, I have read that children of mixed European/Japanese parentage were given the opportunity to either stay in Japan, becoming a member of Japanese society, and never leaving Japan again (i.e. never seeing their father or their father’s country), or, to leave Japan, staying in Dejima or leaving entirely, being considered wholly a foreigner, and never being permitted into Japan again (e.g. to see their mother, their mother’s family or hometown). Obviously, travel and immigration are not nearly as strictly restricted today as it was in the time of “maritime restrictions,” but even so, the idea of a strict artificial division, that one has to be either Japanese or non-Japanese, that on an official, citizenship level, no more complex identities can exist, remains largely unchanged, it would seem.
This official, political, legal stance of forbidding people from both being a Japanese national and holding a foreign citizenship seems all the more bizarre given the familiarity with which Japanese often regard other people of Japanese descent (Nikkeijin). Whether it’s an assumption that Nikkeijin fundamentally understand the Japanese way of thinking, or other aspects of Japanese customs, culture, values, and attitudes, or whether it’s more some sense of belonging, or simply a sort of affinity for the similar, Japanese certainly do seem quite often to show a stronger connection to or affinity for Nikkeijin, both on the personal level, and on more official levels (hiring, allowing one to immigrate to Japan, agreeing to rent an apartment to a Nikkeijin but not to more foreign-looking foreigners).
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Of course, the circumstances of one’s birth are not the other means by which one can obtain citizenship(s). There are many who, as adults, for one reason or another, seek to claim citizenship of another country, whether simply in order to claim a part of their identity that is otherwise not officially recognized, or to move back to the homeland of one’s mothers and fathers, or to adopt a new land as one’s home, either out of genuine national/cultural desire, or more purely logistical motives. If the right career opportunities happen to fall into my lap, I can absolutely see myself moving to Ireland, the UK, elsewhere in Europe, or even elsewhere in the world, and wanting to obtain citizenship there in order to dramatically simplify visa & immigration issues, even if I’m not exactly looking to begin seeing myself as French or German or Italian in terms of my personal, cultural, identity.
All of this is complicated, of course, by the fact that different countries award citizenship differently, treat it differently, and consider it to mean something different. Some countries’ citizenship laws are based primarily on blood, e.g. that if you’re born to Japanese parents, you’re Japanese, but if you’re born to non-Japanese parents, in Japan, you’re still not Japanese. Some countries grant citizenship based on place of birth – if you’re born on US soil, regardless of the citizenship of your parents, you’re a US citizen. Some permit people to claim citizenship relatively easily based on ancestry, regardless of where one was born or grew up, and some do not permit people to give up their citizenship very easily. While this last situation can, understandably, provide a logistical headache for those seeking to avoid having to pay taxes to their home country, for example, while simultaneously paying taxes in their country of residence, in terms of ethnic, cultural, and personal identity, I can appreciate the logic behind this. While taking a citizenship can be primarily for logistical reasons, and I have no ideological problem with that, it does make a great deal of sense to me that renouncing one’s citizenship should be seen as a dramatic political act, and should be therefore taken extremely seriously by nations expecting their citizens to renounce any other citizenships. Renouncing your citizenship means formally cutting ties with that country, refusing to any longer be associated with that country. It means, on some level, no longer being allowed to consider yourself Polish, or British, or whathaveyou, at least in the eyes of that country’s government. And, so, I have an extremely difficult time with countries that force one to renounce all other citizenships when naturalizing.
I have a friend who lives in Japan, and has every intention, it would seem, of living there the rest of his life. It makes a whole lot of sense for him to formally become a Japanese citizen. This will absolve him of having a visa that can ever expire or not be approved for renewal, entitles him to various societal/governmental benefits, and will make it a lot easier (in theory, at least) to get jobs, apartments, etc., i.e. to not be discriminated against as a foreigner. Yet, this also means he will have to give up his US citizenship. Now, I don’t know all the ins and outs of precisely how that works, whether or not the Japanese government can officially look into whether he has renounced that citizenship, or the various ways that he might be able to surreptitiously maintain both citizenships, since each citizenship is wholly outside of the jurisdiction of the other country. But, officially, according to Japanese law, he would have to renounce his US citizenship. This is a big deal. This is a bold political statement saying that one severs all formal connections with the United States, that one officially no longer has any allegiance to the United States, and that the US should from now on consider one to be a foreign national. This means, in essence, no longer being an American at all, but only being a Japanese who comes from, or was born in, the United States. And, it means that every time he wants to go home to visit his parents, or other family & friends, every time he goes home on business, or on vacation, he will have to stand in the foreign nationals line at Immigration. Now, this in itself doesn’t sound like a big deal, and it happens that the US & Japan have agreements such that one does not need a visa in order to simply visit the other country. But, if he ever wanted to (or had to) move back to the US for any real length of time, and if he wanted to ever work in the US, he would need to apply for visas just like any other foreigner. I, frankly, simply cannot do that. I cannot see myself ever doing that.
Whatever your political leanings may be, and I certainly am not the most 100% gung-ho yahoo woo-ee “Go America” type, still I am an American, and the idea of being a foreigner in my own country, of having to deal with immigration and visas and whatever as a foreigner, as if I had never been born and raised here by American parents to begin with, as if I don’t belong at all, is just unbelievable to me. I could never do it. Being American is not the same as being French or Italian or Polish, Chinese, Korean, or Japanese, in that American is not an ethnicity, and the US is not a nation-state in that sense of the word. But, even so, it is an identity, and one that will always be a part of who I am, no matter where I choose to live and work, no matter what affiliations with other countries I may add on in future. As Peter Spiro, a law professor at Temple University, writes:
Acceptance of the status allows the many individuals with multiple national attachments to actuate those identities. In this respect, dual citizenship represents a kind of freedom of association, a form of voluntary affiliation to be protected, not condemned.
In his brief essay in the New York Times today, I do not believe there is a single statement with which I disagree. I encourage you to read it (and to read all of the opinion pieces, as they are indeed quite brief), as I think he says precisely what I would have liked to say, and likely says it better.
David Abraham, a law professor at the University of Miami, argues that for the vast majority of people who are not so socio-economically privileged to be a member of the jetsetting cosmopolitan elite, “the weakening of the nation state and its command of singular loyalties is a loss, a loss of the only kind of tie and commitment that might counter the money and influence of elites — namely, the potential equality and commands of citizenship.” He alludes to an important point – that as nation-states grow weaker, multi-national corporations and the like grow stronger, and this is something we desperately need to be on guard against. However, his argument falls apart when we consider the numerous cases of people from poorer countries coming to a wealthier country to seek better opportunities. Obtaining US or UK citizenship (for example) is an important step for these people to obtain monetary and material benefits, including public education, Social Security, and health insurance (and, yes, I know that in many countries, non-citizens, even illegal immigrants, enjoy many of these benefits too. But, nevertheless..), and perhaps most importantly the benefit of being able to stay and never fear deportation, visas running out, being denied the renewal of a visa, etc. Yet, retaining one’s “home” citizenship is crucial as well, in terms of the strength of identity, the strength of national and nation-state identities. To my mind, it is the denial of citizenships, the forced renunciation of citizenships, the forced severing of ties to one’s homeland, that threatens to weaken the nation-state, not the retention of one’s national affiliations (identity) while one seeks a livelihood overseas.
It is surely a very complicated issue, and I wonder what your opinions and experiences are. Have any of my readers obtained (or been born into) multiple citizenships? What do you think about your own complex personal identity, and about how that complex identity is officially perceived or recognized by national governments?
What a thoughtful and timely article. This is quite topical as many of our friends and acquaintances in Hawaii are faced with this issue upon graduation. It’s exacerbated by the difficulty of securing work visas (a process that seems like it should be simple but in reality is a costly and difficult process). There are not always many options for those trying to make a living overseas as you mentioned, or who feel an affinity for a country they have grown to love, or people they have grown to love but are unable to marry. Good points to think about.
I don’t know much at all about the intricacies of visa/immigration policies and procedures, particularly as it relates to, for example, Canadian citizens in the US, but with Canada and the US being so closely related and intertwined, economically, culturally, linguistically, it seems absurd to me that it should be so difficult for Canadians to stay in the US to look for work. I could go further, to say that there’s no reason it should be as difficult as it is for Brits, Europeans, Japanese, people from friendly countries, from relatively privileged socio-economic backgrounds and good education, who would be a benefit, and not a burden, to US society, to come here and stay here. But maybe that’s a separate matter.
Going back to the Canadian visa issue, I certainly don’t mean to say that Canada is like the 51st state, or is essentially basically just like being part of the US – I know there are differences, important differences. But, we are as close as the UK and Ireland, if not closer… Culturally and linguistically. Geographically in that no other countries are nearby, and that something like 90% of Canada’s population lives within X miles of the US border. Economically in that some huge proportion of US and Canadian exports are exported to one another. And yet, in terms of visa issues and such, it would seem to be more difficult for Canadians to live and work in the US than for people from places as culturally, politically, and socio-economically disparate as the UK, Spain, Greece, Romania, Lithuania, and Germany to travel, settle, and work anywhere within the E.U.
On some abstract level, I guess maybe there are some quality political / economic arguments to be made for Canada/US immigration policy to be how it is, but on a personal level, knowing so many Canadians, Brits, Japanese, who are good people, who are quality people, just as educated, just as dedicated to doing a good job and being a benefit to society as any American, and who have had such a difficult time just staying and living and working in a place that you and I have no such visa problems, I find it extremely frustrating.
I don’t have a problem with people having dual citizenship…as long as they pay their taxes to each country. Most likely the person would participate more fully in the society of 1 of those 2 countries. But in today’ world of available plane flights, jobs that require living in commuting/living in another country as well as family members spread across more than 1 country, it’s just reality. As for bi-national children ie: ” Though I gather this only actually happened in a mere handful of cases, I have read that children of mixed European/Japanese parentage were given the opportunity to either stay in Japan, becoming a member of Japanese society, and never leaving Japan again (i.e. never seeing their father or their father’s country), or, to leave Japan, staying in Dejima or leaving entirely, being considered wholly a foreigner, and never being permitted into Japan again (e.g. to see their mother, their mother’s family or hometown). Obviously, travel and immigration are not nearly as strictly restricted today as it was in the time of “maritime restrictions,” but even so, the idea of a strict artificial division, that one has to be either Japanese or non-Japanese, that on an official, citizenship level, no more complex identities can exist, remains largely unchanged, it would seem.”
I do think that Japan has to think carefully about the half-part Japanese children and be more humane instead of causing more family dysfunction on the citizenship matter.
I think it could not be put better, what you say about Japan needing to rethink their policy to be more humane, rather than causing family dysfunction. They’ve started to make a tiny bit of progress on the issue of child abduction, and allowing foreign fathers rights regarding their children, rather than the situation that has occurred so many times in the past, when Japanese women have essentially fled to Japan with their children, where the Japanese government gives them, essentially, exclusive custody, refusing to acknowledge it as “abduction,” protecting the mother and doing absolutely nothing to help the father.
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As for the separate topic of taxes, it is of course complicated, and there may be various aspects or implications that I have not really considered; but, my kneejerk reaction is that someone should not have to pay taxes twice. We each pay plenty of taxes in our lives as is, and having to pay taxes to multiple countries just because you’re a citizen there seems like it could be quite burdensome.
I remember when I was living in England, my family bought a computer for me in the US, and then shipped it to me in the UK, where I was not able to receive it until I payed VAT on it – even though we had already paid sales tax on it, to the US government, when we bought it. Shipping yourself something you already own, and have already paid sales tax on, should not incur additional taxes. Now, admittedly, as a non-citizen of the UK, I could have saved all my receipts from that year, and reclaimed all the VAT I had paid the whole year. And, admittedly, that’s a different matter from income tax and such, but, nevertheless, if only from the point of view of how expensive it is for the taxpayer, it seems ideal to not have to pay taxes multiple times (to multiple governments) for the same thing.
If I were living in Japan, earning money in Japan, I would want to pay taxes to the Japanese government, and only to the Japanese government. Regardless of my US citizenship, so long as I live in Japan, it’s Japan’s public spending (police, road maintenance, everything) that I take advantage of in my life, and so it is Japan’s tax revenues to which I should contribute. Right? If the US demands income taxes from me as well, so long as I am living in Japan, what are those taxes going towards that actually benefit me? Things that I’ll benefit from if and when I return, I guess, or simply the argument that as a citizen I should want to benefit, to support, my own country. But…