citizenship, passport, expat

As for Germany, German nationality law allows dual nationality under certain, well defined circumstances; for example, a German citizen is allowed to retain his German citizenship if he or she takes out the citizenship of another EU member state (if the that member state's nationality law allows that); another example, if a child is born to a German parent in a country which automatically confers its citizenship to any baby born on its territory ( USA, Canada).

As for Paul Hogan, the issue vis-a-vis Australia was his fiscal domicile when at that time. Apparently he was ill advised by his accountants. He could take out US citizenship, but taxation-wise that would put him in a worse situation as the USA taxes on the basis of citizenship regardless of fiscal domicile. No wonder many USers seek a second passport for expatriation purposes. Countries such ad Dominica and St. Kitts offer economic citizenship programmes for money or real-estate investment, but ex-patriation in the USA is a ten years process which requires you to pay taxes ten years after ex-patriation. Australians don't have that issue.

And yes, it is impractical even to cotemplate obtaining the citizenship of Monaco or Liechtenstein or any other micro-nation for tax purposes. unless your name is Mr.Gates or Mr. Abramovich :-)!

Most of the dual national that I know are either Australian, New-Zealanders, or Canadians who hold British, Irish, Italian, or Greek passports ( very few Maltese, Cypriot an Serbian) Evey fifth Australian is a dual national!

Regarding Australians and New Zealanders, I know they are allowed to live and work in the other country, but would their time in the other country be considered permanent residency, so that after 2 or 3 years they could apply for the other citizenship? I know there probably isn't much benefit in doing so, but then again, laws change, so...

Same question for EU countries - if you're a citizen of one, and move to another, are you automatically considered a permanent resident, and able to apply for citizenship after staying the required number of years (typically 3)?

Speaking for NZ, you can apply for citizenship but need to reside the same length of time as other migrants. .*Been present in New Zealand;

* for at least 1,350 days with a Permanent Resident Permit issued by Immigration New Zealand during the 5 years immediately before you make your application; and
* for at least 240 days with a Permanent Resident Permit issued by Immigration New Zealand in each of those 5 years; *

My children hold Australian passports only even though they would have been entitled to NZ citizenship if their births had been registered in NZ within 2 years of turning the age of majority. Both decided not to so are Australian citizens and NZ permanent residents. For both countries, they had to live a total of 104 weeks to be entitled to any benefits residents are entitled to. My brother and his family live in Australia and hold dual NZ and Australian citizenship mainly to make it easier on reaching retirement age. This goes back over 20 years so rules applied then look like they've changed.

I've got an Australian passport and I find it a fairly handy document.

If I could have another passport I'd love an EU one of some variety as it would open up more possibilities work wise. But, having said that, it isn't a huge deal since travel in Europe is easy on an Australian passport and if I really wanted to work in Europe chances are I could manage to find a job that would sponsor me.

ex-patriation in the USA is a ten years process which requires you to pay taxes ten years after ex-patriation

just wondering, has this law ever been challenged in international court? Seems like the US would have no jurisdiction to collect taxes from a citizen of another country, if they no longer lived in or had investments in the US

The Clinton Administration introduced this legislation in order to discourage would be ex-patsfor tax purposes. The law stipulates that one is libable for paying tax to the IRS ten years AFTER a Certificate of Loss of US Nationality hadbeen issued!

Moreover, the US, EU and Canada have been pressuring any goverment that has an Economic Citizenship Programme. They have shut down Gramanda's, Belize's, Panama's, and it is just a matter of time before the Commonwealth of Dominica and St, Kitts & Navis wrap up their programmes. Canada now requires visa from Dominica passport holders, and the UK is considering following the Canadian example. A real estate agent in London has told me that the Russian mafia has managed to obtain Dominica citizenship. So, people who invested a lot of money in these programmes will eventually have their citizenship revoked. It has become a big issue in Dominica and there allegations on corruption among members of the cabinet,

And no, no one as far as I know have ever challenged the US vindictive law.
This is a unique American issue because the USA taxes on the basis of nationality rather than fiscal domicile.
Australian, Canadian, Brits and other Europeans don't have that issue as their tax is collected on the basis of their fiscal domicile.

This is a unique American issue because the USA taxes on the basis of nationality rather than >fiscal domicile.

Well . . . yes and no.

US citizens living abroad are able to exclude/exempt the first US$91,400. (for tax year 2009)

IRS Publication 54 ( http://www.irs.gov/pub/irs-pdf/p54.pdf ) spells out that IF your TAX home is a foreign country in which you are resident, you may exclude/exempt that first $90k. For must of us on this board, that probably means we won't owe any taxes to the US. In other words, if you are good citizen in the country in which you are residing AND pay taxes there for any work that you do - no problem for the first $90k. US citizens DO have to file to claim the exemption, but any halfway decent accountant can do it for you rather inexpensively and/or it is easily enough done by the individual concerned.

It is really only US citizens who are trying to stay under the radar everywhere and not paying taxes anywhere who are likely to have a problem.

Disclaimer: I am not a tax expert and I have paraphrased the qualification from IRS Pub 54.

Australian, Canadian, Brits and other Europeans don't have that issue as their tax is collected on the basis of their fiscal domicile.

I'm certainly not a tax expert either but the laws have changed this financial year for Australians. I've always claimed Australian residency and not paid tax on money earned overseas. This allowed me to claim the tax free thresh hold on money I earned (rental income) within Australia. Now if I want to maintain my residency I have to declare income earned overseas and pay the difference between the tax I've paid and what I would have paid if I'd earned that money in Australia.

Strangely enough I've suddenly decided I'm not a resident after all.

Australian, Canadian, Brits and other Europeans don't have that issue as their tax is collected on the basis of their fiscal domicile.

My understanding is that Canadians have significant difficulties too - especially if they wish to use their national health care when they return "home". But I will leave it to a Canadian to explain those issues.

Don't confuse residency and fiscal domicile!
You are right, Taxation-wise, an Australian citizen is liable for any income generated inside the juridiction, but if you hold an off-shore company that is registered in say Panama, or Antigua, you don't have to pay tax if you hold an Australian passport but lives in a yet another country. It is call the Five Flage Structure.

For example:

1 You hold an Australian passport.
2 You company is registered in Panama
3 You live in the Barbados on your Australian passport
4 You bank in Switzerland
5 You spend time in Toronto and London where you rent a flat.

This structure is good for countries that tax on the basis of finacial domice.

An American citizen would have to find a second passport because he or she are taxed on the basis of their citizenship.

For example:

1 You hold an Italian passport (based on an Italian born grandfather)
2 You leave the USA and rent a property in the Canary Islands ( Italian is an EU passporty)
3 You dive; that is, you simply don't renew your US passport (no need to give up US citizenship)
4 You register your company in Panama
5.You bank in Liechtenstein
6. You spend time in London, Berlin, Nassau
6