As the world becomes increasingly interconnected, embracing the concept of dual citizenship can prove to be instrumental in harnessing a range of global opportunities while fostering a sense of security and adaptability. There are many ways to apply for citizenship, and you may be eligible even if you don’t think you are. Here we offer something of a roadmap, guiding you through the benefits and considerations of dual citizenship in today’s dynamic landscape.
Some Advantages of Dual Citizenship
Given the uncertainties of today’s geopolitical and economic landscape, acquiring an alternative citizenship may be worth considering as both an insurance policy and as an investment for the future. U.S. citizens are allowed to hold one or more additional citizenships, without losing their U.S. citizenship, and dual citizenship can serve as a strategic tool, helping to navigate the complexities of the globalized world, mitigating the risks that may arise from relying solely on one passport.
Visa-Free Unencumbered Travel. Having a second passport enables individuals to be recognized as citizens of two countries. One of the most tangible advantages of dual citizenship lies in the ability to travel more easily between countries without the typical constraints faced by those considered to be foreigners. Depending on where you choose to travel, the visa process can be time consuming and change frequently. For example, beginning in early 2024, U.S. citizens will no longer be allowed to travel to Europe without applying for advance authorization through the European Travel Information and Authorization System.1 With dual citizenship, travelers may avoid strenuous visa application processes and visa fees, as they often enjoy visa-free access to a broader range of countries. This streamlined travel experience allows individuals to travel without the worry of the complexity, cost and time required to get necessary documentation.
Even if you have a second home outside of the U.S., there are limitations on how many days a year or how many days in a row you can stay there depending on your visa type. Having a second passport offers greater flexibility in how often and for how long you visit. This can be particularly beneficial when familial ties extend across borders.
Lifestyle & Retirement Benefits. One of the most significant advantages of dual citizenship lies in the flexibility to choose where to live and retire, as dual citizens can settle in either of their countries of citizenship. If the additional citizenship is from an EU member country, the dual citizen actually has a choice of 27 different countries, known as the Schengen Area, where they have the right to work, study or retire.
Moreover, dual citizenship in some cases may grant access to an extended range of social benefits and services in both countries. This includes healthcare, education, and various social welfare programs, allowing retirees to enjoy comprehensive support systems and a high quality of life.
The advantages of dual citizenship have the power to transcend generations. Depending on the specific citizenship requirements of your chosen country, you may have the opportunity to extend the benefits to your children and grandchildren, leaving a lasting legacy of opportunities for future generations.
Multiple Routes to Dual Citizenship
There are various avenues through which you can become a dual citizen. Each has their own particular advantages and the suitability of any of these options will vary depending on the country or countries where you might wish to acquire citizenship and your personal and financial goals.
Citizenship by Lineage. This is a commonly overlooked path to gaining citizenship in another country. Citizenship by lineage, also known as “citizenship by descent,” enables you to claim citizenship based on your familial ties and ancestry. The process typically involves proving a direct bloodline connection to a family member from the country of interest. The eligibility criteria and documentation requirements vary from country to country, with some more strict and others more flexible. If you are interested in potentially pursuing this option to acquire second citizenship, you’ll need to look carefully into your family history as well as be careful to adhere to the specific regulations of the country in question. While some countries restrict this option to just one generation, there are others that grant citizenship to individuals with family histories that span much further back. While this option may often entail an initial cost to gather the necessary documentation, typically with the help of a professional genealogist, the cost is likely to be significantly less than would be required for citizenship by investment. The process from start to finish can take from 1 to 3 years depending on process and backlog for the specific country.
Citizenship by Investment. Some countries offer citizenship in exchange for a substantial financial investment in private companies, real estate or government funds. Over 100 countries in the world have some form of citizenship or residence by investment program in place , including Turkey, Malta, and Spain. The requirements for citizenship by investment programs vary from country to country. The types of investments that qualify can include real estate purchases, investments in government funds, and investments in designated sectors of the economy. Each country has its own set of financial thresholds and eligibility criteria that applicants must meet, but it can be another way to help achieve both your financial and life goals. Investing overseas can result in additional tax filing requirements so it is important to work with a professional to understand all the implications in advance of the process.
Golden Visa Programs. If full citizenship is not your initial goal but you would like residence in another country, there are residence by investment programs, also known as ‘golden visas,’ that make this possible. This provides a fast-track way to obtain temporary residency in your country of choice. The requirements for a golden visa vary from country to country, however, similar to the citizenship by investment pathway, it involves making some kind of investment within the country. By fulfilling the necessary residency conditions, individuals may have the opportunity to transition to permanent residency or even citizenship in their desired destination. For European Golden Visas such as Portugal and Greece, you also gain the ability to travel freely within the Schengen Area. It is important to work with a professional as these programs change frequently and at times may be closed entirely.
Examples of Popular Golden Visa Programs
Portugal2
Residency Requirements: Five-year residency program; Involves renewal every two years; Must spend a minimum of seven days in Portugal in the first year and a minimum of 14 days in subsequent years to maintain the residence. To meet naturalization requirements, one must spend a minimum six weeks annually for five years.
Qualifying Investments:
– Minimum investment of €500,000 in a venture capital fund
– Capital transfer of a minimum of €5 million
– Real estate purchase of minimum €500,000, or €350,000 for construction more 30 years old or in designated urban regeneration areas with intent to refurbish. Some additional restrictions may apply depending on location and commercial vs. residential real estate. (Note: The real estate option is under consideration by the Portuguese government and may not be available in the coming year.)
– Company formation (creation of at least 10 jobs)
– Charitable donation of a minimum of €250,000 up to €500,000 depending on recipient of donation
Greece3
Residency Requirements: Five-year residency program; Renewal every five years; No minimum stay requirement but the qualifying investment must still be held.
Qualifying Investments:
– Minimum real estate investment of €250,000 (up to €500,000 depending on location)
– Minimum investment of €400,000 in any of the following: Greek government bonds; Bonds or shares of real estate investment companies in Greece; Shares and bonds of venture capital funds and private equity which have headquarters in Greece.
Important Considerations When Deciding to Pursue Dual Citizenship
Having dual citizenship or residence offers significant advantages, however there are tax implications that you should carefully consider before going through with the process. The tax consequences of holding citizenship or residence in two countries can be complex and may vary depending on each country’s tax laws and regulations. One of the key considerations is tax residency, as dual citizens may be considered tax residents in both countries, potentially leading to double taxation on their worldwide income. U.S. citizens pay taxes to the U.S. federal government regardless of their place of residence, therefore if they move their residence abroad, they are still bound to their U.S. tax liability. Tax treaties between countries may provide relief from double taxation through tax credits or deductions. However different countries have different treaty agreements, so it is important to understand the provisions of those treaties in order to optimize tax planning. Compliance with tax filing requirements in both countries in which you reside or hold citizenship is essential in order to avoid penalties. It is important to hire a professional who is familiar with the tax laws in both the applicable countries as this process can get particularly complicated.
Estate and Inheritance Planning. Dual citizenship can also present unique estate and inheritance planning implications and opportunities that require careful consideration. One of the key aspects to address is the potential application of estate and inheritance taxes in both countries where the individual holds citizenship. However, with proper expatriation planning and establishment of a domicile of choice in a country which does not have estate, gift or wealth taxes, there is a potentially valuable estate planning opportunity.
Each country will have its own tax laws governing the transfer of assets upon death, which could result in double taxation if not managed effectively. Proper estate planning becomes essential to minimize tax liabilities and ensure that assets are distributed according to the individual’s wishes. Additionally, understanding the differences in inheritance laws between two countries is crucial, as they may impact the distribution of assets and the rights of potential heirs. Having dual citizenship can affect the choice of beneficiaries and trustees for trusts established in either country. Seeking professional advice from estate planning experts with knowledge of international tax laws and regulations is vital to developing a plan that aligns with your overall goals.
Dual citizenship offers a range of opportunities and benefits, but it also comes with important considerations and responsibilities. Understanding the tax and legal implications is crucial to navigating this journey successfully and we are here to work with you and experts in this field as you navigate this process.
1Afar. “It’s Not a Visa—But U.S. Citizens Will Need to Register and Pay a Fee to Travel to Europe in 2024.” July 24, 2023.
2Servicio de Estrangeiros e Fronteiras. (Portuguese Immigration and Border Service.) “Applying for Residence in Portugal: Article 90-A – Residence Permit for Investment Purposes.” Accessed September 15, 2023.
3Enterprise Greece. “Residence Permits.” Accessed September 15, 2023.
This article was researched and written in part by our 2023 summer intern, Tiambie Kone. We are grateful to him for his time and effort and to the Posse Foundation for connecting us.