By Mark Fritz
Los Angeles Times
April 6, 1998
Jesus R. Galvis came to America, built a business in New Jersey and got elected to the City Council of Hackensack. Last month, he decided to expand this American success story by running for the Senate. The one in Colombia. Galvis was attempting a feat perhaps unprecedented in American politics: holding two elected offices simultaneously in two countries. He is, after all, a citizen of both places, with a pair of passports to prove it. "I was going to travel back and forth," said Galvis, who runs a travel agency in Hackensack. "I saw this as a good opportunity to keep some ties to the homeland there."
He lost, however. But the fact that a public servant from an American city campaigned for a post in a foreign government is but one example of a growing global phenomenon: dual citizenship. For better or worse, some analysts say pledging allegiance to more than one flag is becoming the hot status symbol of the coming century. "You can now live in two societies at the same time," said Mark Krikorian, executive director of the Center for Immigration Studies in Washington. "This is an issue of significant concern worldwide."
Years ago, voting in a foreign election was a good way to lose your U.S. citizenship. No longer. While the federal government doesn't endorse dual citizenship, it increasingly tolerates it, at a time when more countries are allowing it and more people are seeking it. A second or even a third passport has become not just a link to a homeland but also a glorified travel visa, a license to do business, a stake in a second economy, an escape hatch, even a status symbol.
In the last seven years, Colombia, Ecuador, the Dominican Republic and most recently, Mexico -- the suppliers of some of the fastest-growing immigrant groups in America -- have allowed their nationals to become citizens elsewhere without losing their original nationality. New leaderships in South Korea and India have expressed support for the same idea.
Upscale Australians in the United States have been pressuring their government to allow dual citizenship so they can become Americans without losing their native status. The main motivation? Avoiding the stiff estate taxes that the U.S. government imposes on foreigners who work here. "The whole issue is just an aggravation. [Australians in the U.S.] feel discriminated against," said Helen Cameron, who traded her Australian citizenship for American nationality so she could do business, serve on the school board and even seek the mayor's seat in Irvine.
Portable Patriotism Is On the Rise
Signs of portable patriotism, a sort of citizenship of convenience, are everywhere. In Denver, an American sells passports from Belize to Russian nouveaux riches looking to broaden their travel privileges. In Toronto, an immigration lawyer custom fits his clients with whatever citizenships will help them navigate global markets. One Canadian tried to get his son an Italian passport as a graduation present.
Last year, a French Canadian with a U.S. passport ran for mayor of Plattsburgh, N.Y. He argued that the incumbent spoke French too poorly to be running a city so close to Quebec. He lost. Also last year, a retired top American official for the U.S. Environmental Protection Agency ran for president of Lithuania. He was inaugurated in February to a burst of fireworks. Even some of his fellow Chicagoans had been able to vote for him.
In 1996, Dominicans from New York not only could vote in the Dominican Republic's presidential elections for the first time, they could vote for a New Yorker. And Russian Jews in Israel could help decide whether to reelect President Boris N. Yeltsin. Multiple nationalities have become so commonplace that some analysts fear the trend is undermining the notion of nationhood, particularly in the place with the most diverse citizenry on Earth: the United States.
Debate over the issue intensified last month, when Mexico joined the growing list of poor nations that say it's OK for their nationals to be citizens of the countries to which they have migrated. Under the law that took effect March 21, Mexicans abroad -- most of them in the United States -- will be able to retain Mexican citizenship even if they seek U.S. citizenship. And naturalized Americans of Mexican descent will be able to reclaim their original citizenship. The Mexican government stopped short, for now, of giving expatriates the right to vote.
"It's hard to overestimate how important the Mexico situation is," Krikorian said. "There are now 7 million Mexican-born people in the United States. That's almost a third of all immigrants." Krikorian is among those who say dual citizenship hinders assimilation and undermines the sense of shared experience that makes a nation a community. These critics say dual citizenship reduces the United States to a place to make a buck, a mere land in which to live while blood loyalties lie elsewhere. "I think people think, 'So what. We're all democrats today. What's the big deal?' " said Noah Pickus, an immigration expert at Duke University's Sanford Institute of Public Policy. "[But] if you make citizenship strictly a passport, it doesn't have much substance to hold people together."
Others disagree. They say the trend toward multiple nationality is just a sign that the world is shrinking, that accessible transportation and easy communication as well as regional trade agreements and the globalization of the marketplace have created a new world of porous borders, a place where issues and agendas are more regional than national. It reflects the growing interrelationship of the world," said T. Alexander Aleinikoff, former general counsel for the U.S. Immigration and Naturalization Service and a leading authority on immigration law and citizenship. "Some people think of dual nationality as bigamy. Another way to look at it is having your family, and then when you get married, you have someone else's family as well. You may have to negotiate where you spend Christmas."
Many Latinos in America are troubled that people get alarmed about dual citizenship trends in Latin America, while other regions are rapidly unifying. "Europe is coming together. Asia is coming together," said Adriano Espaillat, a naturalized American from the Dominican Republic and a member of the New York State Assembly who is the first Dominican elected to a U.S. statehouse. "I think that Irish Americans are still Americans first," he said. "Latino Americans are Americans first."
Limitations to Land Loyalties
Yet even people who actively promote the idea of dual citizenship say there are limits to subdividing loyalties. New York City Councilman Guillermo Linares, the first Dominican American elected to any office in this country, made it a point not to vote in the 1996 Dominican election, the first in which Dominicans abroad could vote. "I am an elected official of the United States," Linares said.
Although Galvis' candidacy for the Colombian Senate was virtually unknown to the U.S. public, it was the topic of much debate in the local Colombian community. Saramaria Archila, head of a Latin American social services agency in Queens who had lobbied for the dual citizenship law in Colombia, nevertheless said Galvis crossed the line. "If I am an elected official in a country, it is impossible to defend the interests of my community in another country," she said.
Galvis, asked whether he could represent his Hackensack constituents while splitting time in Colombia, said he would have been like a U.S. congressman with an office in his district and one in Washington. In each place, he said, "I would be representing the Colombians in the United States."
The U.S. State Department reserves the right to revoke the citizenship of Americans who vote in foreign elections, seek a foreign citizenship or run for foreign office, yet almost never does. During the last 30 years, the courts have sharply limited the State Department's ability to revoke citizenship, except in the case of the occasional Nazi war criminals who seem to surface on a regular basis.
In recent years, in fact, the rules have made it easier for people who dodged the Vietnam War by fleeing to Canada to come home and resume their citizenship. By 1994, the U.S. rules had been liberalized to the point where even Winston Churchill, who had an American mother, could easily claim U.S. citizenship if he were alive today.
Some other examples of tacit U.S. support for dual citizenship:
Losing U.S. citizenship is not easy. "About the only way you can lose your citizenship is if you renounce it," said Robert Mautino, a San Diego immigration lawyer who has written on the topic. Only 612 Americans lost or renounced their citizenship in 1996, about a third of the number as during some of the Vietnam War years. Occasionally a billionaire will renounce his citizenship to avoid paying taxes. Ted Arison, founder of Carnival Cruise Lines and owner of the National Basketball Assn.'s Miami Heat; and John Dorrance III, heir to the Campbell Soup fortune, saved millions by renouncing their U.S. citizenship.
Dual Citizenships Usually Accidental
Dual citizenship mainly happens by accident, when foreigners have a child in a country, like the United States, that bestows citizenship on anybody born on its soil, or when two people from different countries get married. Yet immigration lawyers say they are seeing an increase in the number of people who actively seek an extra citizenship. And more than half the countries in the world now allow people to keep their citizenship even after acquiring another one. Or two.
"For poor countries, one incentive for embracing dual citizenship is the economic stake it can give them in the United States," said Hiroshi Motomura, a professor at the University of Colorado School of Law. "Many countries rely on remittances from countrymen who make decent wages in the West and send cash to their relatives back home. "The presence of a significant contingent in the United States really amounts to a significant form of foreign aid. In some cases you have remittances exceeding exports, like in El Salvador."
The trend toward tolerance of dual nationality has coincided with enormous changes in the world during the last 10 years, one of the great periods of migration in history. This vast movement of people was triggered in large part by the fall of the Soviet empire and the opening and realignment of countless borders. One out of every 100 people on Earth lives outside the land of their birth. Added to that is the globalization of the marketplace and the rise of the big trade alliances, such as the North American Trade Agreement and the European Union. Factor in that it's easier to maintain ties to more than one country, thanks to the availability of cheap transportation and communication.
"I don't think this is a trend that's going to abate. I think it's going to increase." said Peter Schuck, a Yale Law School professor who has written extensively on the topic. Schuck believes dual citizens are more an asset to the United States than a threat. "One advantage is that if they continue to vote in their original countries they would infuse their home countries with American values." He cited the 1996 Dominican Republic presidential election, one of that nation's most honest and orderly. Others say dual citizenship threatens to turn the United States into an amorphous piece of real estate that lacks a national identity.
Canada, which legalized dual citizenship in 1977, is now "more like an airport than a country," Pickus said. He said Canada is being forced to rethink its liberal citizenship rules in part because people from Hong Kong are now using Canada as a security blanket in case China imposes authoritarian rule on their homeland. "They're saying: 'Hey, we don't want to live [in Canada]. We just want it as a backup plan,' " Pickus said. Canada has become something of a convenience store for citizenship kits. Lawyers advertise its advantages around the world. Some, like Toronto attorney Guidy Mamann, are experts at cobbling together all sorts of combinations.
Ethnic Iraqis or Palestinians are typically eager to seek an extra citizenship so they can get more visas and travel to more places without having to disrobe at the border. Customs agents around the world assume even the most law-abiding Iraqi is an agent or terrorist. "They are frisked from top to bottom. They are refused visas," Mamann said.
People Build Up Passport Portfolios
Some people build up portfolios of passports. Mamann said he's working on the case of an American with dual Israeli citizenship and permanent residency rights in Hong Kong who is seeking permanent Canadian residency as a prelude to citizenship. This would enable him to, for example, do business in Cuba. "He will have three or four passports and will use the one that suits him the best," he said. "And this is only going to continue. People are going to want to acquire as many nationalities as possible."
Patrick D. Lennon, an immigration lawyer in Hamilton, Canada, spends evenings at home with his wife listening to Italian language lessons on a CD-ROM. They aren't Italian, but they're working on it. A few years ago, with the Canadian economy in the doldrums and the European Union preparing to turn itself into one big market, he thought it would be wise to get his son Italian citizenship when he graduated from college. "I thought, 'God, this would be a real bonus to hand him another market for job search," Lennon said. "I looked at my own Irish ancestry to see if there was something there, and it was a dead end. And I looked into my wife's Italian ancestry, and there was something there."
His son found a job, but Lennon and his wife, whose mother emigrated from Italy as a child, were intrigued by the idea of moving to the EU themselves. He's been piecing together the paperwork for five years and figures he's a document or two away. Lennon sees nothing wrong with such designer citizenship. "We don't expect all these other cultures to meld into this homogenous landscape called Canadian, whereas the Americans expect everyone to come together into this one big Disneyland," he said. "That melting pot thing really doesn't work." The American ideal of assimilation, Lennon contended, is passe. "People who were more or less conned to believe that the minute they saw the Statue of Liberty they become an automatic American are reaching back for their origins."
Every country in the world seems to have a slightly different take on just what constitutes citizenship and nationality, and what it takes to tamper with it. A few years ago, some West African nations extended dual citizenship to black Americans in a bid to build old bridges broken apart by slavery. Dr. Christian Barnard, the South African heart transplant pioneer, was granted dual citizenship in Greece because it was the birthplace of Hippocrates, the father of medicine. After the author Mario Vargas Llosa lost his bid for president of his native Peru, his countrymen literally found they wouldn't have old Vargas Llosa to kick around anymore; he took out a second citizenship in Spain. "Ever since I was young, it has been my ideal to become a citizen of the world," he told a Times reporter last year.
Some countries don't like that. Ulf Samuelsson, a National Hockey League player, was booted off the Swedish national team during the Winter Olympics in Nagano because it was found that he also had a U.S. passport. Sweden, liberal in so many ways, considers people no longer Swedes if they take citizenship somewhere else. Samuelsson's defenders said he got U.S. citizenship so he wouldn't have to keep applying for a U.S. work permit every year, the sort of coldly pragmatic rationale that drives critics of dual citizenship crazy.
Dual citizenship has been an explosive issue in such conflict-ravaged countries as Rwanda, Cambodia and the former Yugoslav federation, where the balance of power sometimes rests with people forced to flee murderous regimes and who subsequently become citizens somewhere else. Britain began embracing the idea of dual citizenship to protect its nationals abroad when it began granting independence to its various colonies. Russia did much the same when the Soviet Union broke apart.
Many people say that Latin American nations are affording the same sort of protection for their people in the United States, where anti-immigrant sentiment is high and benefits have been sharply curtailed. Some analysts see the retention of property rights in Mexico as the significant part of the dual citizenship law because more Mexicans would be likely to become U.S. citizens if they knew that they could keep home ownership in their native country.
U.S. Citizenship Often About Cash
Aleinikoff said that some people have always sought U.S. citizenship for economic reasons, and whether they have dual citizenship is irrelevant. "It is important to take citizenship seriously and cultivate in citizens a sense of loyalty and commitment and sacrifice that comes with being a citizen of the United States," he said. "If the United States is successful about doing that, we have very little to fear about dual citizenship."
Yet U.S. citizenship is often just about cash. In 1989, when Congress eliminated the ability of foreigners to claim the same exemption on estate taxes that U.S. citizens got, "The Brits dashed down and got U.S. citizenship right away," said Philip Minter, an Australian American from Philadelphia. This disturbed Australians working here, he said, because that country doesn't recognize dual citizenship. Well-heeled Australians in America, including media mogul Rupert Murdoch, have been pressing Sydney to recognize dual citizenship for years.
Minter was born in Australia, married an American woman and got a job as chief of information for the U.S. Centers for Disease Control and Prevention in Atlanta in 1968. To keep that job, he became an American and gave up his Australian citizenship. Minter, 69, said his late father never got over the fact that a son renounced Australian citizenship. "He just felt I let the side down." His father cut him out of his will, "which cost me a fantastic amount of money," said Minter. He wouldn't say how much, but Helen Cameron, an acquaintance, said it was $1 million.
Minter later went to work for the Australian Chamber of Commerce in Philadelphia and decided to reapply for Australian citizenship. It was granted last year because, he said, he was able to prove that he took on U.S. citizenship under duress. Today, though, he said he has no doubts about where his allegiance lies. "I've lived in Philadelphia for 30 years. I consider myself a Philadelphian."
The surge in dual citizenship comes at a time when the number of Americans born outside the country has risen to nearly 10%, double what it was three decades ago. The number of Americans born elsewhere was once up to 15%, in 1910.
Scott Wasmuth, director of a nonprofit refugee relocation agency in New Jersey, deals with a particular type of immigrant. These are people from Liberia who have managed to survive seven years of merciless combat by avaricious warlords. Or families from Bosnia purged from their homelands by their fellow citizens. They are different from most immigrants in that their lives were so threatened, their living conditions so deadly, they were granted political asylum. To these immigrants, Wasmuth said, U.S. citizenship is more than a passport, economic benefit or immigration status one notch above green card. "Citizenship should be about ideals."
