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  • Writer's pictureParviz Malakouti-Fitzgerald, Esq.

The Insider Lingo of Dual Citizenship (Mobility Concepts)

Updated: Jun 30

By Parviz Malakouti-Fitzgerald, Esq.

This article is part of our series on mobility concept & strategy explainers

To use mobility strategies, you need concepts, and to understand concepts, you need language.

To that end, let’s take our fictional character, Max Mo Vilidad (“Max”) through a short journey to freedom of movement, hitting all the important lingo and buzz terms along the way.

Becoming a Dual Citizen

Max is a 32 year old entrepreneur and citizen of the United States. He’s accumulated a net worth of a few million dollars. Long term, he’s not sure what he wants to do, but for now, he knows he wants to get started on a combination of citizenships and residencies. He wants a mobility asset portfolio (or a passport portfolio) to increase his global freedom of movement and residency.

These immigration residencies are different from tax residency, which is where a country might deem Max resident for the purposes of taxing him.

Max read about flag theory and is intrigued by the idea of treating countries like an à la carte menu. This could mean having your work or business in one country, banking in a second country, raising your family in a third country, keeping assets in a fourth country, etc.

Max’s motivations are multifold. First, he wants a Plan B citizenship to have a safe, reliably accessible home in another country in case the U.S. heads in a direction he doesn’t like.

If he succeeds, Max will become a dual citizen. He may even want to get a third citizenship and become a triple citizen. Either way, he’ll be a multiple citizen.

Ancestry, Documents, & Unions

Through consulting with a global mobility lawyer, Max learns he likely qualifies for Irish citizenship by descent (“CBD”) through his grandfather, Eugene. That’s because Eugene was born in Limerick, Ireland before immigrating to Philadelphia in the 1920s.

Doonagore Castle, Ireland

In preparing to apply, Max runs into roadblocks getting his grandfather’s birth record from Ireland. This is an unfortunate instance of document dependence - Max qualifies, in theory, for the citizenship, but is unable to obtain a necessary document to prove it.

Aside from the ancestral affinity, Max is in love with the idea of Irish citizenship because Ireland is a member of the European Union (“EU”) and therefore Irish citizenship would make Max an EU citizen, with the indefinite right to springboard into residence in any of the 27 EU countries.

Ireland is also a member of the Common Travel Area (“CTA”) so Max would be able to springboard into residence in England, Wales or Scotland if he becomes an Irish citizen.

MERCOSUR and CARICOM are two more examples of such travel unions, similar to the EU.

MOAR Citizenships

Max’s success in business has put him in a financial position to also afford citizenship by investment (“CBI”).

He likes the idea of naturalizing i.e. becoming a citizen, in St. Kitts & Nevis, by making a non-recoupable donation of about $150,000, including application, due diligence and lawyer fees. “Citizenship by investment? More like citizenship by DONATION!” Max thinks. But alas, both are covered by the term CBI.

St. Kitts citizenship provides the benefit of visa-free travel to the European Schengen zone, a (usually) borderless zone in the EU. Max’s Irish citizenship will already afford him visa-free access to the zone but Max loves the visa-free redundancy he’d get by adding St. Kitts citizenship.

Youthful Indiscretions

Unfortunately, when Max was 22, he was convicted of DUI in California, an offense that shows up on Max’s FBI background check (“FBI identity history summary”). This is an issue because nearly all citizenship by investment processing units (“CIU”s) require American applicants to submit the background check, and they don’t look kindly on convictions

Fortunately, Max’s lawyer was able to expunge his DUI conviction. Expungement is a form of post conviction relief, so-called “clearing of a conviction” in colloquial terms.

Max’s attorney is also writing a legal opinion letter to submit with Max’s St. Kitts citizenship application. The letter explains the law and sentencing of Max’s conviction and advocates on behalf of Max. Max successfully naturalizes in St. Kitts, becoming an economic citizen.

Plan B Residencies & Semi-Citizenships

Through research, Max thought he might also qualify for a “Karta polaka”, a somewhat rare semi-citizenship, through his Polish great-grandfather. Max ultimately learned he didn’t qualify.

Even though Max is already set to become a triple citizen, he feels comforted by the idea of even more mobility assets so he looks into applying for a Plan B residency.

Max’s lawyer explained that most countries require substantial physical presence, i.e. days spent in the country over a period of years, in order to qualify for naturalization. But not all of them! In some countries, you can become a resident, spend minimum physical presence there on a day by day basis, but yet still be eligible to naturalize after a few years.

In the industry, some call this “absentee residency”, “fictive residency”, or “paper residency.”

Max got residency in one of these countries. He doesn’t want to say which one publicly; it could bring negative scrutiny and ruin a good thing.

Related: Global Mobility Services for Americans

Max’s Freedom of Movement

So Max is now a triple citizen of the United States, Ireland and St. Kitts. Max also has residency in a fourth “mystery” country. Max has achieved the indefinite right of residence in the USA, St. Kitts, Ireland, all of the EU, all of the CTA, plus his mystery country of residency.

And hopefully, you’ve now learned 30 critical new terms of dual citizenship lingo…

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