Citizen pain: the ordeal of dual nationality and the U.S.

Opinion

Hey there, time traveller!
This article was published 01/02/2025 (253 days ago), so information in it may no longer be current.

Be careful what you wish for.

First, a whole bunch of background: I was born in the United States, but my family moved to Halifax when I was three years old.

Canada is the only country I’ve ever felt like I belonged in. I am Canadian.

But I had to spend years of my life waiting, and thousands of dollars, to give up my American citizenship.

I had to wait five years for an appointment, and then travel hundreds of miles on my own dime and my own time to the only available U.S. consulate — in Ottawa — that could have me sign the papers I needed to sign to surrender citizenship.

And then I had to pay even more. The following is the main part of the checklist for giving up U.S. citizenship: “For fee payment, please bring a money order made payable to the UNITED STATES DEPARTMENT OF STATE in the amount of $2,350.00 U.S. We do accept credit cards but have found that some credit cards do not work for this fee and cards are often declined. We accept cash (U.S. only) in exact change.”

Fair enough. Countries make their own rules and set their own fees.

Some of those other rules?

If you hold American citizenship, even dual citizenship, and live in a foreign country, you’ll be required to fill out U.S. income-tax documents every year, and pay U.S. taxes as well as Canadian ones if you earn above a certain amount. (The U.S. also doesn’t recognize some Canadian tax shelters like Tax-Free Savings Accounts and Registered Education Savings Plans, among other things.)

You’ll also be required to file specific documents on every single investment you own or even share an interest in over US$10,000, every year — if you don’t, you can face tens of thousands of dollars in penalties. The penalties can be larger, in fact, than the accounts you’ve failed to disclose.

Oh, and if you get any of the process wrong, as I understand it, the U.S. can rescind the cancellation of your American citizenship, just so they can take civil action against you or criminally charge you as a U.S. citizen all over again.

(That’s only a thumbnail — if you hold dual Canadian-American citizenship and this is the first you’re hearing of this, consult a skilled accountant and perhaps a lawyer.)

It’s an almost uniquely American approach to taxation and citizenship — only Eritrea and the Philippines also tax their citizens, even dual citizens, in whatever country in which they live and work.

You could say it’s left me with a deep distrust of many facets of the American governmental system.

Don’t get me wrong: I’ve visited parts of the U.S. I truly love. Sunset on the Nevada desert, with the ground’s range of defined reds and oranges and sages vanishing into velvet darkness, is like nothing else. Individual Americans? Often, a treasure.

But get back to the way the U.S. treated someone who chose to be a Canadian citizen decades ago. I tell you all this for a reason: if any Canadians are under the impression that Canadians would get some kind of sweetheart deal out of joining the U.S., where Canadian funds would be matched at par with the American dollar, etc., they’re dreaming in Technicolor.

I can’t imagine even Trump’s kowtowing Republicans would allow equal representation — and equal votes — for Canada’s 40 million people, especially because 65 per cent of Canadians traditionally vote for left-of-centre parties like the Liberals, the NDP and the Bloc Québecois, and even Canada’s conservatives don’t have a record of being as hard-line as U.S. conservatives. How many Canadian conservatives, for example, would agree to surrender Canadian medicare?

After all, a strong share of left-leaning Canadian voters would easily tip federal elections towards the Democrats, and, given that the Canadian population is larger than California’s, we would change the make-up of the U.S. Congress permanently. So don’t expect to be able to vote.

Instead, the offer would be a form of American statehood lite, along the lines of what Puerto Rico’s 3.2 million or so American citizens get: citizenship with an asterisk, and real statehood some indefinite time in the future that’s unlikely to ever come.

The biggest part of the difference for Puerto Rico? No elected members of congress for the region, no senators and no ability to cast a vote for president, unless you live outside Puerto Rico in a different part of the U.S.

My guess is Canadians would not only get a second-class form of U.S. citizenship, and probably have to guarantee a healthy up-front payment — in U.S. currency, of course — just to be eligible for that eagle-embossed passport. As the U.S. stumbles towards not being able to afford Social Security, imagine what would happen to your CPP?

Don’t believe me? Just look at their record.

Taxation without representation sounds like a violation of one of America’s foundational principles — but Puerto Rico has never had a congressman, nor a senator.

And effectively, the diaspora Americans (close to 5.5 million U.S. citizens, with over a million in Canada) living outside the U.S. don’t either. (They get a vote, but they aren’t really in anyone’s constituency.)

The U.S. government is about expediency and political pragmatism, not principle. Believe otherwise, and you are rubes being led to the snake-oil slaughter.

Russell Wangersky is the Comment Editor at the Free Press. He can be reached at russell.wangersky@freepress.mb.ca