Since we’ve started our Canadian citizenship application process recently, some folks have been curious what this will mean, practically, when all is said and done. How much will things change for us once we’ve passed our exams, taken our oaths, and received citizenship status in Canada? The answer may surprise you.
Not a lot! To be honest, the biggest differences will be conferring citizenship to our descendants and voting rights. We also might need to decide which passports to hold. Beyond that, neither of us have immediate plans to run for elected office, join the military, or fly to space under our new flag just yet. To understand all this more fully, it helps to start with what “dual citizenship” is exactly, and how immigration status works differently in Canada versus south of the border.
Dual citizenship, which can more properly be thought of as an example of multiple citizenship, is not typically an official status recognized by any one nation or country. Rather, it simply refers to the situation of a single person simultaneously holding citizenship status in more than one place. To each of those places, as far as their local laws are concerned, you’re generally only regarded as a citizen of that jurisdiction. Some countries do not permit or recognize dual nationality, but many do, including Canada and the United States of America. It is even possible, though uncommon, to hold citizenship in more than two places at once (like Mark Carney does).
The other concept that comes into play here is permanent residency, which generally refers to a status allowing a non-citizen person to reside in a given country “on a permanent basis.” Every nation on the planet defines this differently and, unlike citizenship which is typically understood similarly from place to place, permanent residency varies greatly from one country to another (or in some places, is not available at all).
In America, permanent residency is synonymous with having a “green card” which is the credential such persons receive. In the states, this status is politically volatile, and a green card holder can find themselves facing an unforeseen status adjustment for any number of reasons…including the whims of a regime change. Some government agencies in the USA do not typically afford the same constitutional protections or due process to green card holders as native-born or naturalized citizens.
In Canada, permanent residency is comparatively easier to attain, harder to lose, and for most practical purposes nearly equivalent to citizenship in everyday life, especially when it comes to the Charter of Rights and Freedoms. Many who immigrate to Canada and become permanent residents choose to remain so for many years, without much concern over suddenly having their status revoked, much less being deported. Even the most fervently anti-immigration political forces in Canada only tend to advocate for limiting new arrivals, not for taking status away from those who are already here legally. The most common ways that Canadian permanent residents tend to “lose” PR status is by either living abroad for too long, or deciding to take their oath to become a citizen (as one status replaces the other).
For immigrants to Canada from the USA, another dimension to all this (whether you choose to keep your PR card or become a dual citizen) is taxation. There are numerous books on this subject but the essential concept to understand is that, just like bucking the metric system, the United States is unique among the nations of the developed world in that it taxes its citizens every year of their adult lives no matter where they live on the planet. In case that’s hard to believe or you think you’re reading it wrong, here’s a direct quote from the IRS…
If you are a U.S. citizen or resident alien living or traveling outside the United States, you generally are required to file income tax returns, estate tax returns, and gift tax returns and pay estimated tax in the same way as those residing in the United States. Your income, filing status, and age generally determine whether you must file a return.
…in other words, unless you’re a still a dependant minor, no matter what country you might earn a living in, Uncle Sam wants his cut!
For Canadians, however, there is good news. Since 1983, shortly after Canada adopted its modern constitution, there’s been a tax convention (with amended protocols since 2007 and and an information exchange agreement since 2014) with the USA that limits income liability for any citizens of one country living and working in the other. In essence, you can apply a significant amount of the taxes you pay on one side of the border against what you may owe on the other, reducing or even eliminating “double” taxation.
There’s a lot more nuance to it than that, and you can pretty lost in the acronyms (FATCA isn’t FACTA, for example) so anyone new to life as an ex-pat should definitely consult a “cross border” tax preparer for at least their first few years, to make sure they withhold wisely and file properly with both the IRS and CRA. The only way for an American citizen to avoid this responsibility altogether is to renounce their American citizenship, which is a pretty severe move (thought some have chosen to do so for financial reasons). Be advised, however, that the USA even taxes expatriation itself.
While this complication may sting a little every April, there’s another bright side to retaining dual citizenship between Canada and the USA every November…and that’s keeping your right to vote!
Given some of our own motivations for leaving the USA, this is a big deal to us and should probably be to anyone considering such a move. If you’re a citizen of the United States living in another country, including Canada, you are considered an overseas citizen voter and can still participate in federal elections, remotely.
Registration can seem a little confusing sometimes, since that’s done state-by-state, and therefore you’ll need to maintain a spot on the voter rolls in the last jurisdiction you lived in before immigrating. To make things easier, the Federal Voting Assistance Program offers a universal postcard application to make sure you get the job done without missing any deadlines. We’ve successfully done this a couple times now, checking our registration status online and mailing our ballots back and forth. In case you’re curious, Canada offers its own citizens the same service while residing abroad. One wouldn’t want to miss an election up here while visiting extended family across the border, after all.
Dual citizenship has its ups and downs, but in our case (at least until something major changes politically someday) we are looking forward to expanding our national identities, and keeping up with our international responsibilities, as we continue to expand our global experience. Whether that may change for us someday, or for our children when they reach adulthood, remains to be seen. For now, though, we’re focused pretty narrowly on taking things step-by-step. Wish us luck!
This Ontarian Life 