When Lt. Col. Alexander Vindman, a decorated US war veteran, was smeared on Fox News recently for implied “dual loyalty” because he had been born abroad, I was doubly offended. First, because someone who emigrates from a country at the age of three isn’t torn by dual loyalties; a toddler has no choice in the matter. Second, because an increasing number of folks — myself included — have legitimate “dual loyalty” in that we hold more than one passport, and the second passport may arrive after we have reached the age of consent. But that doesn’t — shouldn’t — make us suspected double agents.
The fact is, spies and scoundrels aren’t the only ones who can scrounge through a desk and pull out more than one passport. There are millions worldwide, including Daniel Craig, who plays the cinematic spy James Bond, and his wife, actress Rachel Weisz. They are citizens of the US and the UK. Singer Michael Bublé is Canadian and Italian. Director Martin Scorsese is Italian and American. Entertainer Ricky Martin is American and Spanish. Current British Prime Minister Boris Johnson was, until fairly recently, a citizen of the US as well as the UK, until he gave up his US citizenship for political expediency. The list goes on.
But why would someone want two passports? Why would someone have three (or even four), which also happens? One could ask Mark Carney, a governor of the Bank of England, who was a leading contender to head the International Monetary Fund earlier this year. By tradition, that position is headed by a European, while an American heads the World Bank. The Canadian-born Carney would not normally have been in the running. But he had an ace up his sleeve, or more precisely, two additional passports in his drawer — British and Irish. Irish nationality made his candidacy theoretically palatable to the French and Germans who would otherwise have rejected him out of hand. Unfortunately, they did anyway, reportedly because an Irish passport was not considered European enough. According to Reuters, “a senior French official said that President Emmanuel Macron wanted a ‘continental European’ for the job.” (It eventually went to Bulgarian Kristalina Ivanova Georgieva-Kinova).
Multiple passports were not the issue. Since 2018 the chief economist of the IMF has been a dual citizen: Gita Gopinath carries both Indian and US passports.
But why? Why would people carry two passports, with all the problems they create (read on)? And why would governments allow them to do so?
The reality is that many countries don’t allow dual citizenship — Austria, China, Japan, India, and Indonesia among them. And very few countries where dual citizenship is allowed, including the US, look favorably on it because of the possible complications. On a fundamental level (quite different from a Fox News level), it is reasonable for a government to want to know where your loyalties lie.
For example, the US oath of allegiance for naturalized citizens includes the phrase:
I absolutely and entirely renounce and abjure all allegiance and fidelity to any foreign prince, potentate, state, or sovereignty of whom or which I have heretofore been a subject or citizen.
So in case of conflict between one country and another, what happens?
Where does an age-eligible person do military service? If he or she serves in the military of one country, are they exonerated from serving in the country of the second passport? Which country would they choose to die for, if the situation arose? The same applies for women as well as men in countries such as Israel where both sexes are obliged to serve in the military. Fox News would go berserk, and even more enlightened minds have to grapple with these issues for which there are no simple solutions.
My sons studiously avoided the problem. The US does not have obligatory military service nor does Italy, the country of their second passport. Italy did have obligatory service when they were born, so they waited till after draft age to apply for their second passport.
What about security? Dual passport holders are viewed with suspicion when applying for security clearance in government because of the possibility of divided loyalty. Even the lowest level security clearance in the US includes an investigation of one’s interests; red flags start waving if those “interests” include receiving financial benefits from another country.
Years ago I applied for a job in the US government and had to pass security clearance. I had no problems, but the fact that I was married to a non-American DID create some concerns.
Income tax obligations are another grey area for multiple passport holders . . . but only if one of their passports is from the US. The United States is the only country in the world (aside perhaps Eritrea) to impose citizenship-based taxation. So wherever in the world you may live, an American is obliged to file a tax return each year to Uncle Sam. That applies even if you owe no taxes, even if you have not lived in the US since infancy.
Legal issues can create nightmare scenarios for dual passport holders. For example, if a Yankee wants to marry a non-American and live outside the US, he or she is best off financially by giving up control of his/her assets to the foreign spouse. Or one can surrender control to an arrangement structured to take advantage of the laws where one is living. This changes by country and also within countries, depending on regional tax structures.
Inheritance is another mine-ridden situation. A dual UK and French citizen who wants to leave his or her estate to one member of the family will be able to write a will doing so in the UK. But not in France, where the law is specific about how an estate will be distributed. The estate of a dual citizen of the US and Italy will face no inheritance taxes for the first 5.5 or 11 million dollars in the US, but primary family members (spouse and children) in Italy who inherit more than 100,000 euro have to pay four percent to Rome.
The children of a dual citizen couple may also have dual citizenship, meaning that one parent can travel with them to another country without the other parent’s knowledge. This has happened in acrimonious divorce cases, sometimes without legal recourse.
Business investments are more complicated because of different rules applied by different fiscal authorities. The definition and financial treatment of partnerships can be different. The definition of a holding company can be different. Treatment of year-on-year tax profits and losses may be different.
Above and beyond how the law treats you, a more fundamental question is how you treat the law . . . because that can change dramatically from country to country, as well as from individual to individual. Scandinavians and Greeks have conflicting attitudes toward tax obligations, for example. British and Chinese have different understandings of “the rule of law.” Israelis and Indians hold dissimilar views of children’s citizenship rights.
And yet the solution to dual nationality is not false accusations or internment camps à la World War II. At World Cup time, my sons’ loyalties are clear: they paint their faces in red, white, and green, and they wave the Italian flag fervently. On Thanksgiving, they baste turkeys and heap on the cranberry sauce.
Me too. I live in Italy and vote in both countries and celebrate holidays on both sides of the Atlantic. Dual citizenship is complicated but DUAL loyalty does not necessarily mean DIVIDED loyalty. It’s obvious that passports are political documents (and passport holders are people), but to date, the world’s politicians have not figured out how to deal with them . . . and us.