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Dual Citizenship

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  #1 (permalink)  
Old 15th August 2007, 05:19 PM
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Default Dual Citizenship

Does anyone here have dual citizenship? Are you a citizen of more than one country? Is it hard to do? Do you have to pay taxes to two different governments?

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Old 15th August 2007, 07:26 PM
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Yeah, there's a good question. I've been looking into that myself. An American acquaintance of mine here in England told me she has to pay taxes to both countries because of dual citizenship. I'm planning to just take the citizenship test once I'm eligible. I'd have nothing left of a paycheck otherwise!
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Old 18th August 2007, 01:19 PM
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I am a Brit and will always stay a Brit , i am proud of my heritage , it gave me what i am today , for what ever that may be worth .
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Old 20th November 2008, 06:58 PM
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Depends which dual citizenships you're talking about!
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Old 20th November 2008, 07:08 PM
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Quote:
Originally Posted by Penguins_Pet_Pumpkin View Post
Yeah, there's a good question. I've been looking into that myself. An American acquaintance of mine here in England told me she has to pay taxes to both countries because of dual citizenship. I'm planning to just take the citizenship test once I'm eligible. I'd have nothing left of a paycheck otherwise!
Sorta misleading.

As an American citizen she is taxed on her worldwide income irrespective of her residence. As a UK citizen or resident she is taxed as a resident. So, the fact she naturalized as a British citizen makes no difference here -- it is the fact that she's resident that generates the tax.

For the American citizenship, there's a large lump sum (70 or 80k or so) that's tax free for those living abroad. After that, there's a dual taxation agreement between the US and UK that alleviates some of it. You can still fall into traps though where this agreement doesn't cover it. But the vast majority of dual citizens should pay no more tax, either because their income is not high enough or they planned it properly.

For British citizenship if you don't want UK tax liability, just leave and that's the end of the matter.
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Old 20th November 2008, 07:10 PM
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Originally Posted by oddball View Post
I am a Brit and will always stay a Brit , i am proud of my heritage , it gave me what i am today , for what ever that may be worth .
Funnily enough, I'd guess that many Brits who take dual citizenship with the US are doing so because they're leaving the US and returning to Blighty -- it's the only guarantee of the right to return to the US!
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Old 22nd November 2008, 11:30 AM
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I agree with Fatbrit (what a name :-). You're not generally liable to pay taxes in several countries, although the UK has introduced taxes for non-Brits living in the UK (aimed at all the oil-and city-milionairs living there). Generally, you only need to pay taxes for the country you work/ live in, especially in the EU.

The one useful point to note, though, is compulsory military service - if this applies to the country you're a citizen of. If you're a Greek living in the UK (whether UK citizen or not) you're still liable for military service (unless the laws have recently changed).

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Old 22nd November 2008, 08:32 PM
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We will become citizens of Australia when we can because it's easier to get in and out the country BUT we will still be paying tax in the UK because we own investment property there.

I think that no matter what citizenship you have if you own property in other countries you pay tax there too (we pay the tax in the UK and have to declare it in our Australian tax because we are taxed on worldwide income living in Australia). We are about to go through this for the first time since moving - tax is so much fun!

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Old 22nd November 2008, 10:30 PM
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Tax-wise, you'll probably always get hit by the country (or countries) in which you own property. (Especially investment property - if it generates income, the state wants it's share!)

Normally, you'll pay your primary taxes to the state in which you are resident. There are only a few countries (of which the US is the main one) where you pay (or at least have to report) taxes due to your nationality. It's a pain, but it usually can be handled fairly easily unless you have vast passive sources of income. (It takes me about 20 minutes a year to complete my US tax returns - and I wind up paying no taxes to the US as all my income is "earned.")

Military service is a consideration for those contemplating dual nationality. The other big consideration is that of whether or not your potential nationalities allow dual nationality. Germany, Austria and a few other northern European countries won't allow you to take their nationality without renouncing your prior national ties. Some laws are changing, and it is now sometimes possible to retain, say, your German nationality even if you take a second nationality - however you have to show that you have active ties back to Germany.
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Old 23rd November 2008, 03:02 AM
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The US used to require that you formally reject all previous nationalities. For Britis citizens this was a formality only, since they don't recognize it. And the US has no control over what rules the British set up.

You will always be liable for tax in any coutry where you have income, whether it is from property, interest or dividends on investments, work, royalties, whatever. The real problem is whether that income will be taxed by your home country, too. The US taxes your worldwide income, regardless of source, with an exemption for the first $80,000 of earned income (wages). Usually you can offset taxes paid to the country where the income occurred when filing taxes for the country where you have citizenship, but that is not always the case.

Other countries don't tax you on wages earned outside the country, but do go after dividend and royalty income.

In general, try and find an international tax attorney or accountant, and if you are moving on any kind of expat package, ask that all tax preparation be paid for by your employer.
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