UK dual citizenship

[NickD 203]

Of a country, sorry was interrupted, and accidentally hit post.

[Trompe le Monde 1,107]

I think a lot of the confusion arises because the US doesn't "recognize" dual citizenship but that doesn't mean it doesn't allow it.

Which means to the US government you will always be a US citizen (unless you denounce it)so you must always enter and leave the US on your US passport and file your taxes

[lynJer 7]

One of the Economists in the bank back in Australia and I were discussing dual citizenships about a year ago.... he is a UKC. He told me to be careful when considering taking on usa citizenship as it can have detrimental tax implications.

According to Ben, who had worked and lived here in the USA, but now was working & living in Australia......he looked into the UK/USA dual citizenship when he had been working here but decided against it as it caused issues on Tax for those with a Britsh passport. He mentioned that, should you work in Sth Africa for an example you will be taxed at the USA rate and not the British or Sth African rate......Odd..??

I mentioned to Ben....beauty as Australians are taxed at the highest rate in the world anyway...but he said under the UK passport he determines what tax he pays if he was working in a foreign country...but American Citizens cannot - they still are required to pay tax at their countries rate regardless of where they work....

[Trompe le Monde 1,107]

you are required to FILE your taxes no matter where you work...the first $90k or so of earned income are completely exempt from US. Taxes you pay to the country where you are working are credited against your US tax bill, so if you are working in a country where the tax rates are higher than the US you will not pay more tax, but if they are lower (UAE, Hong Kong, Singapore, etc)you will still be paying US tax rates on everything you earned above $90k.

[lynJer 7]

you are required to FILE your taxes no matter where you work...the first $90k or so of earned income are completely exempt from US. Taxes you pay to the country where you are working are credited against your US tax bill, so if you are working in a country where the tax rates are higher than the US you will not pay more tax, but if they are lower (UAE, Hong Kong, Singapore, etc)you will still be paying US tax rates on everything you earned above $90k.

Thank You....at last this has been explained to me....so therefore...for Australians to consider taking up USC they really do need to take this information carefully.

Or does it not matter .... US residents are still under this law?

[Trompe le Monde 1,107]

US residents still have to file taxes on all worldwide income. For example, if your husband did a freelance job or project for someone in Australia while he was the the US he would still need to list that income on his US taxes.

If in a few years time you decided to move back to Oz (or moved anywhere else outside the US) and he never became a citizen it would not be an issue.

Something to think about with regards to citizenship - it's the one thing holding my husband back from taking it at the moment since we believe we will move back to the UK at some point in the future.

[Brother Hesekiel 2,236]

The only country that I am aware of that absolutely does NOT allow dual is China.

I believe you, but there's more to this.

Whenever we talk about "dual" citizenship, it's actually one citizenship and another citizenship (or even more), but since there are 195 countries in the World, there are more possible constellations then I could figure out with my limited math skills.

Canada and the U.K., for example, are totally cool with dual citizenship. The US recognizes it exists but does not encourage it. Germany and Austria would require a special permit or their citizens would automatically lose their citizenship when naturalizing. India does not allow dual citizenship but has a hybrid, the Overseas Citizenship of India (OCI). Denmark, China, Russia, and a few other countries prohibit it. Saudi Arabia will prosecute its citizens if they assume another citizenship (think pain, lots of pain!), so we always have to look at the policies of the countries involved, not only in regard to their stance on dual citizenship, but also in regard to tax laws.

For a Brit, Canadian or Aussie, becoming a US citizen in addition to their original citizenship is a no brainer. Period. I say "period" because I compare it to staying an LPR, as the US taxes the US citizen as well as the LPR on their worldwide income.

Indians may think long and hard, and so do people who will lose their original citizenship. For the rest, it's research before lifting the hand and swearing off all loyalty to their former country of citizenship.

[Brother Hesekiel 2,236]

Could you answer a quick question along this line for Germany? My fiance has duel citizenship with Germany. We are going through the K1 process so we can marry and she can become a USC. She doesn't want to give up her German citizenship entirely, and I would like our children to have duel citizenship as well. Would I be able to also apply for duel citizenship with Germany? Now I read another forum and it said only children of German citizens, but, perhaps with a marriage I can apply and carry both passports, if not, at least our children can. Second, my fiance's passport is German, but she still already has dual citizenship (not with the UK, but she's living and working in the UK under her German passport) - Would she have to give up either citizenship to become a USC as well? Thanks for your help, we're both fairly ignorant of the process.

I'll gladly answer your question in detail, but you'll need to be more specific. You are a US citizen, I assume, and your finance is a German and ??? citizen. Did she gain her citizenship at birth or by naturalization? When was that?

I'll check back in to this thread either tonight or tomorrow.

Whutz your name?

Bob.

Bob what?

Just Bob!

[Nero 17]

I'll gladly answer your question in detail, but you'll need to be more specific. You are a US citizen, I assume, and your finance is a German and ??? citizen. Did she gain her citizenship at birth or by naturalization? When was that?

I'll check back in to this thread either tonight or tomorrow.

Whutz your name?

Bob.

Bob what?

Just Bob!

Thanks for getting back to me so quickly. Yes, I am the US citizen (by birth). My fiance is Brazilian and German. She was born in Brazil. Her father is German (from Germany), and it is from having a German father that she has German citizenship. I don't believe she ever lived in Germany, but she does have German citizenship / a German passport. She would like to keep her German passport as well because of the European mobility. Right now our top priority is getting through the K1 process, but looking forward this would be good to know. Thanks again

[Nero 17]

BTW: OP and other VJers who have dual citizenship. When you and your fiance filled out your forms (I129F etc) how did you list your citizenship? Did you list one country or both? Also for those who listed both, how did you determine which to post first? Just curious. Thanks!

[VanessaTony 3,567]

As an Aussie we don't have to become USC do we? I do not want to give up my Aussie citizenship and plan on just being a permanent resident here as who knows what the future may hold. I am not giving up my Aussie passport and don't really want a US one.

You don't lose Aussie if you get USC. That I'm 100% sure about, it was the UKC dual I wanted confirmation about

[VanessaTony 3,567]

BTW: OP and other VJers who have dual citizenship. When you and your fiance filled out your forms (I129F etc) how did you list your citizenship? Did you list one country or both? Also for those who listed both, how did you determine which to post first? Just curious. Thanks!

I went as Australian because I was applying in Australia also because I was born there. I also have dual UK so had I applied from there I would have shown UK but apparently they still go by your country of birth anyway (so my GC says "Australian" and would even if I wrote UK on the forms).

I tried to show my UK passport at the K1 interview to have it on record or something but I was told it was irrelevant. I actually used my UK passport pages entry stamps as proof of entry to the US (I was in the UK when I visited the US) and had no issues. The CO couldn't have cared less that I had 2 passports.

[NickD 203]

BTW: OP and other VJers who have dual citizenship. When you and your fiance filled out your forms (I129F etc) how did you list your citizenship? Did you list one country or both? Also for those who listed both, how did you determine which to post first? Just curious. Thanks!

You like most of us were only born in one country, they ask for your place of birth and a birth certificate of that country with a translation if required.

Then to come here, you need some kind of a passport, if different from the country you were born in, obvious that you were naturalized in that country, may ask for an ID from that country as well and a spot to fill that out on the form. They want a complete photo copy, every page of that passport as evidence, for your interview, have to bring in that passport.

I am so confused on this issue, I will never be normal again, when my wife and I tried to enter Colombia, she was denied entry with her US passport, and the POE officer has the full power to deny that entry. But when she called the Colombian consulate about getting a Colombian passport, that officer told her she should have been allowed to enter, as being naturalized in any country, in this case, the USA, her Colombian citizenship was automatically relinquished. She should have been allowed to enter as a tourist. But when my wife told him what happened, he said, maybe you should get a Colombian passport after all.

When I was down in Colombia, asked two notaries for a copy of the law that states once one is naturalized, where is it written that one relinquishes their Colombian citizenship if naturalized in a different country. Was never given that, even in Spanish. When we got back here, asked the DOS for a copy of the law that states your place of birth must be stated in your US passport, never got that either.

So dealing with two different countries that do things without being able to source the law!

[Nero 17]

You like most of us were only born in one country, they ask for your place of birth and a birth certificate of that country with a translation if required.

Then to come here, you need some kind of a passport, if different from the country you were born in, obvious that you were naturalized in that country, may ask for an ID from that country as well and a spot to fill that out on the form. They want a complete photo copy, every page of that passport as evidence, for your interview, have to bring in that passport.

I am so confused on this issue, I will never be normal again, when my wife and I tried to enter Colombia, she was denied entry with her US passport, and the POE officer has the full power to deny that entry. But when she called the Colombian consulate about getting a Colombian passport, that officer told her she should have been allowed to enter, as being naturalized in any country, in this case, the USA, her Colombian citizenship was automatically relinquished. She should have been allowed to enter as a tourist. But when my wife told him what happened, he said, maybe you should get a Colombian passport after all.

When I was down in Colombia, asked two notaries for a copy of the law that states once one is naturalized, where is it written that one relinquishes their Colombian citizenship if naturalized in a different country. Was never given that, even in Spanish. When we got back here, asked the DOS for a copy of the law that states your place of birth must be stated in your US passport, never got that either.

So dealing with two different countries that do things without being able to source the law!

I'm sorry for all your troubles. I think I've had easier(and more pleasant) root canals!

[Brother Hesekiel 2,236]

Thanks for getting back to me so quickly. Yes, I am the US citizen (by birth). My fiance is Brazilian and German. She was born in Brazil. Her father is German (from Germany), and it is from having a German father that she has German citizenship. I don't believe she ever lived in Germany, but she does have German citizenship / a German passport. She would like to keep her German passport as well because of the European mobility. Right now our top priority is getting through the K1 process, but looking forward this would be good to know. Thanks again

Once your fiance becomes a US citizen, she automatically uses her German citizenship unless she has applied for a Beibehaltungsgenehmigung from the German Government. Like many government things, this one's completely insane and consists of 2 parts:

1) Proving that the applicant would experience an actual and immediate hardship if not naturalizing, and, at the same time,

2) Proving that the strong ties to German would make it also a hardship to give up the German citizenship.

The whole thing is a game requiring to know how to play it. Most Germans have problems with part 1 but my guess is that your fiance would have problems with part 2. Basically applicants list all their family over there, their bank account, retirement account, the times they fly over and visit, and so on. If your fiance never lived in Germany, that's almost impossible to pull off. Thus, she would have to choose between becoming a US citizen or keeping her German citizenship as entry pass to the European Union.

On the same token, if you desire to become a Brazilian or German citizen, you would have to be petitioned by your then spouse and move there. After a certain amount of years as a lawful permanent resident and passing a language test which is much, much harder than the one in the US, you could apply for naturalization.