GLOBALCIT Review Symposium on Ana Tanasoca, The Ethics of Multiple Citizenship, Cambridge University Press, 2018


Ashley Mantha-Hollands, WZB

In the Ethics of Multiple Citizenship, Ana Tanasoca engages with some of the difficult questions surrounding the consequences of dual or multiple citizenship. In doing so, she forces the reader not only to reflect on the challenges posed by multiple citizenship but also to look at the institution of citizenship in general. The book is theoretically rich, and while the intended audience is political theorists, the writing is sharp and accessible for those from a wider array of disciplines. Tanasoca offers a refreshing theoretical lens to the question of multiple citizenship. The guiding theme is that multiple citizenship is not morally problematic in and of itself; however, the implementation of the status leads to undesirable moral and political consequences. Tanasoca concludes that these problems can be mitigated through three policy reforms; an unbundling of rights associated with citizenship, making multiple citizenship an active choice, and a global tax or reform to double taxation agreements.


Contributions to the Literature

Tanasoca offers three important contributions to the literature on citizenship: historical, methodological, and conceptual. First, her comparison of investor citizenship to the selling of noble titles is compelling. It brings in a historical perspective on this current and politically salient issue. The second contribution is Tanasoca’s methodological exercise on assessing the compatibility of multiple citizenship with three boundary-drawing principles. It is within this analysis that she finds her third and strongest contribution to the literature which is to ‘unbundle’ the rights associated with citizenship. As Tanasoca writes, ‘although…people should enjoy all the rights comprised by the citizenship bundle somewhere, they do not have to enjoy all of them necessarily inside the same state’ (p. 172). The concluding chapter lays out five possible implementation designs and specifies their advantages and disadvantages. The challenge for this proposition is ensuring that there is some global governance on citizenship in order to guarantee that every individual enjoys the full citizenship package. Furthermore, one can advance this proposal by arguing that it is not only the rights associated with citizenship that can be ‘unbundled;’ rather, it is the whole citizenship package.

This functional or instrumental approach to citizenship separates the four components of citizenship; status, identity, rights and duties, and civic participation. One can easily conceive of a reality where political participation and certain citizenship rights are only associated with residency, while identity and other rights are associated with a different state altogether.[6] One of the undesirable consequences that Tanasoca rightly points to when citizenship is treated as a sum of all its parts is that dual citizens can access social and economic benefits from two states instead of one. Since individuals are unlikely to give up their secondary citizenship due to loss aversion bias as Tanasoca argues (p. 47), or for other instrumental and sentimental reasons such as mobility and family ties, unbundling the citizenship package can offer states an opportunity to cast the boundary net wide, without the potential political or economic consequences. In fact, some states have already adopted this model. In Canada, for instance, citizens can only access generous social benefits (such as health care and unemployment insurance) if they reside within the country for more than six months of the year.[7] This policy dilutes the effects of supporting a population who has access to benefits in two countries.


Critique – Empirical Justifications

As theoretically incisive as Tanasoca’s book is, some arguments lack enough empirical evidence to justify their normative claims. I will point to three issues that need further empirical support and two normative conclusions that weaken Tanasoca’s overall argument. First, to justify her argument about how the preferences of dual citizens undermine collective rationality, Tanasoca starts by working off an assumption that multiple citizens will participate in the elections of their two states of citizenship. Despite the fact that she points out that within the literature this is a highly contested issue, she moves on to argue that because at least some dual citizens will vote in two state elections, it is enough to defend her theory (p. 87). But even this thin version is empirically doubtful. Studies have indicated low participation rates of external citizens (Spiro 2016, 97) and some scholars have even argued that dual citizens will likely focus their efforts in only one state (Schlenker 2016, 522). While states mostly allow external voting, there are barriers that make it difficult to participate, such as requiring individuals to be within the country to vote, or to travel to an embassy or consulate. In the 2016 elections in the United States, for instance, only 6.9% of the 3 million eligible US overseas voters actually voted. Even if one agrees that some dual citizens participate politically in both states, it is unclear whether that number is significant enough in order to undermine collective rationality or to defend policy prescriptions. Therefore, Tanasoca’s argument about dual citizens undermining collective decision-making relies on a contestable assumption and requires further research.

The second empirical question follows the same argument on collective decision-making but focuses on the preference formation of dual citizens and the quality of outcomes. Several studies have revealed that there are no or insubstantial differences in the political behaviour of dual citizens vis-à-vis monocitizens (Schlenker 2016, 518; Wong 2008, 87). Tanasoca argues that multiple citizenship will expose individuals to different – and sometimes competing – reference frames, thus disrupting ‘meta-agreement’ (p. 99). However, competing reference frames can theoretically exist among diaspora communities without the existence of multiple citizenship. After the fall of the Soviet Union, there was a wave of east-west migration to Western Europe and to North America by individuals who had spent their whole lives under authoritarian regimes, a diametrically opposing reference frame to Western liberal democracy. Migration and globalisation blurs boundaries between deliberative groups despite the existence of citizenship. And it would be undemocratic to suggest that these individuals cannot participate in the civic life of the place in which they reside.[8] Tanasoca states that ‘if people vote having in mind different conceptions of what they are voting for, then the outcomes yielded by majority rule will be meaningless’ (p. 86). But first, individuals always have different conceptions of what they are voting for. And, second, it is unclear why nationality is more meaningful then other identity categories such as gender, race, religion, and class. The existence of divergent reference frames is not always contingent on citizenship. Seeing ‘the same big picture’ (p. 97) is unrealistic in plural democratic states.[9] Even if it was empirically tested, the conclusion is also not necessarily a natural outcome of the premise.

A simpler justification for Tanasoca’s reform is that citizens living within the governed space (residency) should be the only active participants in the decisions that affect them, or requiring that an individual should have fulfilled a certain residency requirement at some point after the age of majority in order to participate in the deliberation of the political community.[10] This would at least help mitigate individuals voting without a genuine link to the bounded community. In the citizenship literature that focuses on ius nexi, residence is the most cited criterion that a person must have fulfilled to either gain or maintain the political rights associated with citizenship.

The third empirical flaw is that Tanasoca treats dual citizenship as an indistinguishable category, which does not capture the range of people that hold this status. Throughout the book she maintains that dual citizens represent the global elite, and the reader is left assuming that this class of individuals holds two first tier citizenship passports in Europe and North America. Recent naturalisation statistics, however, show the opposite: one can observe that the majority of individuals gaining a secondary status in Europe are from lower and middle-income countries. Yossi Harpaz (2018, 2; Spiro, 2018, 2) argues that individuals who are seeking a second citizenship are often looking to fill a gap where their original citizenship is insufficient (for example travel). This essentially levels the playing field in order for these individuals to enjoy the full citizenship package. In 2016, for instance almost a third of new Europeans, came from Morocco, Albania, India, Pakistan, and Turkey. 50 percent of total citizenship acquired came from African and Asian countries. In the United States, likewise, previous citizens of Mexico, India, and China exhibited the highest naturalisation rates for the same year. In France, nearly half of foreign-born citizens have only completed a high school level education. While these individuals are perhaps not the global poor, they are also unlikely to be the global elite as she frames them.

Because citizenship laws vary greatly from state to state, the benefits and the costs of dual citizenship cannot be overgeneralized. Possessing two citizenships from Morocco and France[11] offers a different set of opportunities and costs than possessing two citizenships from France and the United States. And sometimes a second citizenship acts more as a burden than a benefit.[12] There are also deep inequalities in how states allow the status to be inherited. Gaining second citizenship in Italy means something different than obtaining second citizenship in Canada or the United Kingdom, where the state limits the inheritance of the status if the following generations are not born within the territory. Access and availability of the status also differs; some states limit to a list the states from which an individual can have access to the status of dual citizenship – for instance, in Latvia, dual citizenship is only permitted with other EU and NATO states. There are also fundamental differences in the way dual citizenship status is achieved – by those born with it, and those who naturalise for it. Treating all dual citizens as if they are the same loses some nuance to why and with how much difficulty that status is reached.


Critique – Normative Conclusions

On the normative side, there are two issues with Tanasoca’s set of policy proposals. She argues that multiple citizenship should represent an active choice, as too often multiple citizenship occurs through default. She thus advocates for a ten year system of renewal. Tanasoca’s argument presupposes that there is no (or little) choice in gaining and holding a dual citizenship. This, I believe, is not self-evident. One can argue that gaining, retaining, and using a status is already an active choice. Citizenship is a form of association. For instance, if multiple citizenship occurs through an interaction of ius soli and ius sanguinis it is a lifelong choice to keep and use that status rather than to give it up or replace it. In order to exercise any of the benefits associated with the status, there are already different bureaucratic processes in place that make retaining the status a regular negotiation. Passports can be seen as a key tangible proof of citizenship – which have to be renewed every five to ten years. And if multiple citizenship occurs through naturalisation, first it is an active choice to go through the process as it requires time, effort, and financial commitment. Individuals can also choose to renounce their second citizenship if the costs associated with it are too high. But above all, it is unclear how Tanasoca’s proposed reform would solve any of the inequality issues with multiple citizenship that the unbundling proposal would not solve.

The second normative issue is articulated in Tanasoca’s argument to reform double taxation agreements or to impose a tax on multiple citizens. Double taxation agreements most often only cover income tax. Dual citizens continue to pay consumption tax when they visit their second state, inheritance tax, and if they own property will have to pay property tax to the state in which the property resides. Thus, dual citizens are not entirely the free-riders that Tanasoca makes them out to be. Reforming double taxation agreements so that dual citizens pay income tax in both their countries or imposing a blanket tax on multiple citizenship could cast the net too wide and would either discourage individuals from naturalising or prompt them to renounce their second citizenship if they could not afford to pay the costs. Tanasoca argues that renunciation of the second citizenship would ‘entail a decrease of the benefits rich people get from being multiple citizens’ (p. 150), however I would argue the opposite, that a tax would keep the status only with the global elite who can afford it.[13] Sara Goodman and Hannah Alarian (2017, 134) find that the allowance of dual citizenship plays a significant role in facilitating a migrant’s decision to move or not. This would likely be the same effect if the state imposed a tax on dual citizenship. From Schlenker’s study on dual citizenship in Switzerland – dual citizens express more attachment, solidarity, and political interest than foreign residents (and no significant differences from monocitizens) therefore, naturalisation can be seen as important for social cohesion and integration (Schlenker 2016, 532).


Conclusion and Thoughts for Further Discussion

The prevailing wisdom in the citizenship literature is that citizenship is becoming lighter; rights and duties that were previously associated with citizenship status are now being protected by the international sphere or associated with residency within a state. In fact, there are two forces at play, as the rights and duties associated with citizenship are becoming lighter; citizenship is also the most important indicator of an individual’s life chances. Tanasoca’s proposal to unbundle citizenship advances the lightness of citizenship and her apt interrogation of the inequality effects of the current citizenship regime points to her understanding of the latter. Her theoretical framework is a strong foundation for social scientists to conduct further empirical research. In her concluding chapter, Tanasoca makes an interesting point against the conventional perception in the literature that dual citizenship dissolves borders rather than enhances them. This is an important debate that merits further deliberation in the future. Tanasoca’s interrogation of multiple citizenship is thought-provoking, and an important meditation on the institution of citizenship moving forward.

This review has received funding from the European Research Council (ERC), Grant No 716350