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by mrsaint 1937 days ago
Our two children are 4 and 6, and they both hold four citizenships.

My wife is US American, I am German, my dad is Croatian and we've been living in Switzerland for almost 15 years.

When the kids were born, they both had US and German citizenship jus sanguinis. German passports arrived almost instantaneously. The US passports required us to visit the US embassy multiple times and fill out plenty of paper work.

Them gaining Croatian citizenship was more involved. First I needed to apply for it for myself through my dad. I also bought a second home in Croatia were we've spent most of our holidays. I also maintain a Croatian bank account that I use to cover local bills. It took several years and a good lawyer to get passed the beaucracy. Ultimately I received the Croatian passport and so did our children about half a year later.

After staying for over 10 years in Switzerland, my wife, my kids and I applied for Swiss citizenship. It cost us a couple of thousand US dollars, a clean record (no outstanding bills, no other credit issues, proof that you can take financial care of the family), proof of "proper integration" (like do I frequently visit the local pub... really!), a German language proficiency test for my wife, and a test for both of us showing that we understand the cultural, religious and political aspects of Swiss society. The process took exactly one year when we received our passports.

Was it all worth it? I think so. It is a liberating feeling to know that you can move between countries. We also wanted our kids to be able to choose for themselves where to live once they are grown up.

7 comments

I hope the kids won't mind having to declare/pay US taxes :)
What you get for your US tax money is absolutely not worth having that passport if you have another good passport. I would give that one up (and likely will once I get my second).
Plenty of expats have gotten more US stimulus cheques than they’ve paid in US taxes.

But it doesn’t make up for the dozens of hours of paperwork and careful tip-toeing on investments and other garbage.

Just an FYI: one hiccup I heard of giving up your US citizenship is that banks didn’t recognize you could be born in USA but not a US citizen.

> Just an FYI: one hiccup I heard of giving up your US citizenship is that banks didn’t recognize you could be born in USA but not a US citizen.

I had this issue just last month with a UK financial institution (Raisin). I tried to explain it but they obviously were not interested. I actually still have my citizenship (I'd love to renounce but that's currently impossible) but I felt it was worth pointing out their policy was unnecessarily discriminative.

Their responsibilities under FINCEN/FATCA are not prove anything, but just have suspicion or some reason to think you might be a "US Person" (not just US citizen, but US resident, or various other special situations).

Of course, the US claims to extra-territorial jurisdiction, and bullying of global financial institutions to enforce their crazy inter-planetary tax system, are totally preposterous.

Elon - renounce before blast-off!

Not to mention, that there are countries that ask you to renounce your other citizenships when taking theirs (Dutch citizenship comes to mind).
When opening accounts in the EU you are asked if you are a US citizen.

You then answer no and that's all, they do not check further.

There may be a check against the form element "place of birth" but I doubt so.

like anything in life, there are tradeoffs. the US passport is great because it allows easy employment access to US tech companies, who pay absurd amounts of money; if you live outside the US for at least 330 days, you aren't taxed federally on the first $105K or so. this allows one to, for example, work 20-30 hrs/week while paying zero federal income taxes to take home around $105K. compare that to NYC: you'd need about $160K to take home $105K (!!), plus your post tax costs aro going to be high as hell - rent, restaurants, and so forth. worse, you're probably pulling 45ish hrs a week for that. i imagine SF is similar or worse.

such a setup allows one to build wealth and live an extraordinary life. i'd highly recommend it if you can swing it.

> US passport is great because it allows easy employment access to US tech companies, who pay absurd amounts of money;

US companies don't pay absurd amounts of money, companies in other countries are the once that don't pay enough. Look at how much wealth tech industry has generated (and still is) for the US companies and the US economy, I think they should pay even more.

Can't comment on how the taxes are spent but having US citizenship can give you access to their job market, in tech this can be a valuable benefit. Op's kids will be able to renounce their citizenship should they wish.
And hopefully they won't ever need a European bank account, or any other kind of financial service. All I ever signed up for, besides asking for citizenship, also explicitly asked for having US citizenship. Presumably checking that box is the immediate end of the application process.
It's not. Checking it means however that the bank will report certain information to US authorities.
Perhaps we're just lucky, but our Swiss bank was okay with it. We only had to guarantee to have a licensed US tax advisor prepare our US tax returns, filing requirements, FATCA/FBAR etc.

While Swiss banks are a bit crazy about anything related to the US (three years ago or so they just stopped accepting US checks from one month to the next, even though they had previously charged a crazy amount of money for it to be cashed in), I heard that banks in neighboring countries such as Germany are less concerned as long as your bank advisor follows some general guidelines.

I personally would not have gotten the US citizenship due to the negative tax consequences (global taxation), but to each their own. Unless you own substantial assets they can still renounce it in the future if interested.
With a Swiss passport and the place of birth being Switzerland, nobody will ever ask them.

If they are asked if they have other citizenship, they can always say Germany - end of the inquiry.

Banks ask everyone during application if applicant have a US citizenship, because of some anti-terror-funding law which non-American banks find onerous. Are you saying the kids should lie and deny being American?
It's not about anti terrorism measures. It about fatca

https://www.irs.gov/businesses/corporations/foreign-account-...

Thanks for the correction!
FATCA is a pain though
>Are you saying the kids should lie and deny being American?

No, you just don't have to say it, you have a swiss passport and that's it.

That's the point. The question is specifically US citizenship because of the onerous reporting requirements it ensues that none of them want to deal with.
Switzerland has a tax treaty with the US which avoids double-taxation.

https://sigtax.com/en/switzerland-united-states-tax-treaty

Yes, most countries do so you're not double taxed. But you still need to declare, and esp. for Switzerland likely pay extra taxes to the US.
The UK has a tax treaty with the US but it didn't stop one Boris Johnson being hit with many thousands in US taxes when he sold his house in spite of having lived in the UK most of his life.
Was his house in the US or UK? If it was in the US the it doesn't matter, the local government is gonna get theirs.
In the UK. The UK has no cgt on your main residence when you sell but the US does.
From what I understand of German law, all of you may have lost your German citizenship, depending on how you handled the Croatian and Swiss paperwork - Germany allows for dual citizenship at birth, however, obtaining any other citizenship means loss of German citizenship unless you have obtained a specific “Beibehaltungsgenehmigung” permit beforehand; so the German passports you have might be legally not valid if you haven't filed for and obtained this permit in both cases (which you hopefully have done).
The Beibehaltungsgenehmigung is outdated in this regard. See https://en.wikipedia.org/wiki/Beibehaltungsgenehmigung
Ah, okay, it does not apply for EU nations (like Croatia) and Switzerland, so it's not a worry for the OP and would matter only if other countries would be involved.
Croatia will be joining the EU in 2023 afaik.

edit: seeing multiple other comments here that is already a member so I guess I am mistaken

It will join the Schengen area next. Also it plans to adopt the euro in 2023.
As a German, why did you get Croatian citizenship for your kids? For sentimental reasons, or were there practical advantages as well?
Sentimental perhaps, because of my heritage, but definitely also practical advantages. For one, citizenship makes owning property in the respective country easier. Also, should my children ever decide to live in Croatia, they could do so, no strings attached. Who knows what the geopolitical future holds? Will the EU still exist in 20 years? Will Croatia still be a member? How will current and future refugee crises shape local immigration laws?
Sorry for the issues with the travesty called the Croatian citizenship law. They are too busy not accidentally giving citizenship to the "wrong" people.

I will vote, no questions asked, for any party proposing a Law of Return for passports, no matter where the person intends to live.

As for the Swiss immigration officials, they are very competent, but I've gotten the impression they always want me to leave back where I came from. I love Switzerland anyway.

>but I've gotten the impression they always want me to leave back where I came from.

It's the same if you move from Zurich to graubuenden :)

> It took several years and a good lawyer to get passed the beaucracy. Ultimately I received the Croatian passport and so did our children about half a year later.

Yeah, it is always advisable to get a Croatian lawyer when applying for Croatian citizenship, for example, even if you know exactly what you are doing.

Croatian law allows for loose arbitrary interpretations of the law by government servants in the bureaucracy. Even if you covered all of your bases and you did everything right, a lawyer stops such issues. Plus, Croatian law regulates exactly how much Croatian lawyers can charge, so it is not bad.

While my citizenship application went smoothly, even without the Croatian lawyer's assistance: If I were applying for US citizenship, for example, I would certainly use a lawyer, although for a different set of reasons. This is something to keep in mind for anyone considering emigrating anywhere, as the stakes can be high.

My guess is that OP’s issue is that only one parent was Croatian so citizenship wasn’t automatic but something to apply for.

Other than gathering all the paperwork, any idea what it’s like if both parents are Croatian? I understand citizenship is automatic not something that needs to be applied for?

It depends on which /Article/ OP is eligible for citizenship under, under Croatian citizenship law. The law has also been updated by our parliament in the past year. I do not want to make any assumptions about OP's situation. When applying for Croatian citizenship, it is important to explicitly state in your "biography" (Životopis) which Article you are applying under, basically as your first statement.

Many people in the diaspora abroad are eligible under Article 11, which can be relatively straightforward but with some "gotcha" tricks, that the bureaucracy will deny your citizenship over. It is vaguely mentioned in Article 11 (in Croatian), that people who emigrated abroad--or people who are direct descendants of these individuals may become citizens, with X Y Z etc. conditions listed as requirements. One "gotcha" for example, is that you have to provide documented official evidence (from at least one government source--certified, Apostilled, and translated into Croatian) that your emigrant family member permanently emigrated from former Yugoslavia. This is not explicitly mentioned as a requirement anywhere in the law. But, implicitly, based on the documentation you would be providing for your citizenship application, you would think that a government servant could determine that your family member established a life permanently outside of former Yugoslavia. The only place where I have found official information about this requirement is on one single Ministry of the Interior webpage, which is in Croatian. (You do not have to speak Croatian at all to become a citizen if you are from the diaspora.)

If you are in the diaspora abroad and your family is from Bosnia, most likely you are not eligible under Article 11, and you are instead eligible under Article 16, which is way more difficult to obtain. Article 16 is way more subjective and arbitrary too, when it comes to requirements, so you can have a tremendously hard time with the bureaucracy.

The articles of the citizenship law (translated into English) appear dubiously straightforward: https://www.refworld.org/pdfid/5ac3799f4.pdf [Note: This is not updated with this year's amendments to the law]

It is a mistake to read Croatian laws exclusively via English translations, regardless of whether they are official translations or machine translated. You miss a lot of context and detail that is needed for success. Croatian is very concise, clean, and direct (with respect to interaction/communication), in comparison to English. The grammatical cases in Croatian contain a lot of context that is missed via human translation and machine translation into English, too.

All applicants must understand that every single Croatian government servant is "thinking in Croatian" when you are interacting with them (or your application), even though their English is fine and they are fluent. When I showed up at the Croatian consulate in Los Angeles, I was told by the consul general (who is now an ambassador in a strategic location in an EU country, to establish better economic ties) that I could not become a Croatian citizen, because the family members that were emigrants were my 4 great-grandparents (I am half Croatian and I am legitimately culturally American and Croatian through my family) from Dalmatia (coastline Croatia), rather than a grandparent or a parent.

I did not expect this "news" but I had come prepared. I showed him the "family tree" I created, in Croatian. Croatian citizenship law allows direct lineal descendants of emigrants, to the third degree, to become citizens. So, he counted the generations of my family, starting with me, and determined, right then and there, that I was right and that I could become a citizen.

The Croatian consulate in LA is the friendliest of all of them, and they actually have a handout now for applying. They also recommend providing a family tree in Croatian. Anyways, it is best to always call--not email consulates: They have to respond to phone calls. Some consulates are better than others.

Page 1: https://drive.google.com/file/d/1iL6ZPKgVj6XpWE8K7VlHocteW6G... Page 2: https://drive.google.com/file/d/1WfhiDrg_VQRZOa6tmh-AxcucuBO...

Some people applying under Article 11 via their emigrant /parent/ have been granted citizenship within 1 month. See: https://vslavich.medium.com/how-to-obtain-croatian-citizensh...

I was granted citizenship off of my 4 great-grandparents (I only needed 1 to be eligible--but I provided full complete documentation for all 4 of them for the Croatian government) via Article 11 in 10 months. But, supposedly a lot more people are applying now during the pandemic, so now the wait is much longer.

If you make the simplest of mistakes; if you are not explicit about your requests; or if your documentation is not organized in a cohesive, easy-to-follow manner, then you are likely going to experience severe trouble. In that case, it can easily take 3-5 years, and you will need a lawyer to resolve your issues in court. One of the best things you can do is have everything, up to the most mundane details, set up to the point where the bureaucracy does not even get the chance to blink at your application. Since they are "thinking in Croatian", it is important to have spatial information in Croatian, such as diagrams and "family trees" if necessary.

Another "gotcha" is on the actual citizenship application form: The Croatian government asks you, in separate questions, "what are your citizenship(s)?", and "what are/is your nationalities?". Croatia, similar to Israel, is founded on the basis of (ethnic) nationality. In other words, your "nationality" is synonymous to your ethnicity. On the application, you are supposed to state "Hrvat" (masculine for Croatian) or "Hrvatica" (feminine for Croatian). They also ask for the "nationality" of your parents. For my mother, I put "Hrvatica", and she is 100% Croatian descent. For my father, it really is none of the Croatian government's business, and I refused to play that game, and I knew I could get away with it via the bureaucracy. I put down "American" as his ethnicity on the application, even though he is of northern European descent. At the consulate, they saw what I did, and they asked me what my father's true nationalities were, which I did answer truthfully verbally. It was kind of funny: It was an awkward situation for the other applicants and the consul general knew to smile and keep his mouth shut, like he had been trained to do.

While Croatians are friendly, some of the government bureaucracy via Croatian diplomatic missions in the US are not-so-friendly. Some people are assigned to the New York consulate due to residing in a state within their jurisdiction.

The New York consulate has tried many times to require that /all/ of your citizenship documentation be less than 6 months old, which is often nearly 100+ documents which includes pages that must be certified, apostilled (authenticated for international use), and translated into Croatian. Due to this strict timeline and ridiculous claim, you basically need to utilize Gantt charts to be successful at this hellbent endeavor. But, if you do your research, and learn some Croatian, you will find a webpage on the Ministry of the Interior's website, explicitly stating that only the criminal background check (in this case: FBI fingerprint background check) has be less than 6 months old for your citizenship application. I have helped many people with this issue.

Many people have emigrant family members who (illegally) transliterated their Croatian names when they arrived in America. A lot of people have last names that officially end with this -ić and their family member changed the ending to -ich upon arrival in America so people would pronounce their last names correctly. The correct way is supposed to be -ic in US English. Some people have family members with the name of "Josip" which the individual changed to "Yosip". Clearly, when the documents are reviewed (birth/marriage/etc. certificates), the name change is noticed and you can still tell that these documents are chained together and tie together the family genealogy which gives entitlement to citizenship under Article 11, for example.

The New York consulate sometimes tries to force people to make the name changes, in proper US English transliteration, on all of the documents. This can be an unbelievable gargantuan logistical task in the US, unlike some other countries. In some cases, it is impossible, because you have to get other family members to agree to change their name, as in their identity--and literally everything tied to it, which they have held all of their life, in order for you to get the documentation right, so you can get your citizenship.

Some people actually do this. But, when the New York consulate tries to pull this stunt off on people, I always recommend getting a Croatian lawyer to take over the battle, so that it is won.

Also, one of the modus operandi in Croatia is nepotism. Connections are crucial, and whom you know gets you places in life. So, one needs to be outgoing and just find people who will help out in situations like this.

Thanks for the post!

I should be eligible under S. 4 where it makes it sound like I'm already a citizen. But yeah, I got the feeling proving it would still be a slow and painful process where it could take a while to gather it all. And I'd only have to deal with 2 parents' records (I think?). They'll be listed as hrvati, but finding originals of the birth certs is a question.

But kinda worried about a parent trying to make an EU trip if ETIAS ever goes live, and being unable to because they don't have an EU passport to travel on. So a lot of paperwork might get sorted out for me anyway.

Just haven't bothered to follow through with it unless I saw myself needing it. And it's increasingly likely I'll be eligible for another EU passport in the near future anyway.

> Just haven't bothered to follow through with it unless I saw myself needing it. And it's increasingly likely I'll be eligible for another EU passport in the near future anyway.

It's chump change to get Croatian citizenship. I only had to pay the Croatian government $235 in 2018 to get it. I was granted it in 10 months. Likewise, getting the putovnica (passport) is easy as can be. I got my Putovnica at the Croatian Los Angeles consulate in the US as soon as I found out about ETIAS.

Remember that Croatia is very pro-EU, for obvious reasons that should never be mentioned (war), so I look at it as a form of insurance. I also use my Croatian citizenship primarily for healthcare, by the way. That is an awful thing to say, but I do believe in the Croatian nation and project and I am definitely Croatian-American, from a cultural standpoint. I have things to bring to the table.

Since both of your parents are legally Croatian citizens, you become Croatian under Article 4 through a form called a "citizenship affirmation" (if I am correct..I could be wrong. You should call, not email the consulate. I would call the LA consulate. They guy who answers the phone is both a Croatian lawyer and an electrical engineer. He really knows what he is talking about when it comes to citizenship matters, and knows them backwards and forwards). This is probably the form you need to fill out for your citizenship application: https://mup.gov.hr/UserDocsImages//2020/Obrasci/Dr%C5%BEavlj...

As you can see, the requirements are written on the bottom of the page.

You will need the Domovnica (citizenship certificates) for both of your parents.

The Croatian government almost never tells you this, but they will retrieve Domovnica, rodni list (birth certificates), etc., for around $67/document. You do that through the consulate you are assigned to, and that is who you mail with the check. This is the form you fill out to get these documents. You also need to make a copy of a driver's license or a national ID card, and enclose it in the envelope, as this is required too. I would also include a written statement with all of this: http://www.mvep.hr/_old/Portals/US/download/ZAHTJEV_ZA_DOSTA...

Typically, the consulates keep this information about retrieving documents under wraps, unless you are friendly with them, and you catch their interest...

But, this is typically the form one would fill out if applying for citizenship, especially if applying under article 11: https://mup.gov.hr/UserDocsImages/dokumenti/drzavljanstvo/ob...

My local consulate has published a guide here with the new changes:

http://ca.mvep.hr/files/file/dmku/ca/Croatian-Citizenship-Ov...

Looks quite permissive.

Applying for US citizenship is actually pretty straightforward unless there is something weird about your case (eg a conviction). Nowadays it can take a lot of clock time. But the application itself (N-400) is easy.
Successfully filling in the application form became more difficult recently. I will soon apply and may well engage a lawyer to check my work since I’m not sure these rules have been rescinded yet. https://www.washingtonpost.com/opinions/the-trump-administra...
Neki sakupljaju marke, neki putovnice... :D
How is this legal? Most countries in the world disallow holding more than 2 citizenships. Do these countries know your kids are holding four? If they do not, they need to be informed.
There are exceptions to the rule (for reference see https://en.m.wikipedia.org/wiki/Multiple_citizenship). Generally, a lot depends on whether you acquired citizenship by descent or birth, or acquired it by naturalization. Also, there are agreements between countries that you must consider.

For example, had Croatia not entered the EU a couple of years ago, it would not have been possible most likely to aquire citizenship for our children without giving up German citizenship. That is because Germany permits multiple citizenship only if you obtained another citizenship by birth and/or the other citizenship is either one of an EU member country or Swiss citizenship. Some with Croatia, which generally allows citizens by descent to have multiple citizenship, but foreigners wanting to naturalize there must renounce their old citizenship (with exceptions, of course). Switzerland on the other hand has no such rules regarding multiple citizenship.

It's difficult to not inform the countries of your multiple citizenship unless you don't apply for passports. With each passport renewal you must also state your other citizenships if applicable.

Anecdote: Shortly after the first child was born, we wanted to visit our relatives in the US. Our child only had a German passport, which we thought would be OK to travel with (because, why not?). Well, as it turned out, once we arrived at US immigration, we were in big trouble. Because our child was automatically a US citizen by descent, she was also required to have a US passport to travel from abroad to the US. This is because formally the US does not acknowledge any of your other citizenships as long as you are US citizen.

Not entirely correct. With a Beibehaltungsgenehmigung you can also obtain other citizenships than what you mentioned and it doesn't need to be by birth. They do make you answer all sorts of questions though to give you that certificate.

Source: we went through it.

We also had a similar-ish experience passport wise while the kids had non-German passports only while we only had a German one. We held up the line of cars waiting to get on the ferry to England (going from the Netherlands) for quite some time while they asked and checked why some Germans were driving Canadian kids to England: o see the Scottish Highlands, duh :)

What GP meant was that USA treated the child as a US citizen by descent, in spite of the lack of a passport, which is why immigration mandated that the child should have been issued a US passport before traveling to the US. It's natural for a lot of countries that allow dual citizenship to mandate that you travel to said country with the passport of that place.
I completely understand and the two paragraphs in my comment are two separate things. One comments on the fact that they said you can only have another citizenship by birth if you want to keep the German one (false) and the other one reminded me of another sort of funny passport and different/dual citizenship situation from my life, which is why I said "similar-ish". Emphasis on "ish".
My wife is from Hong Kong and we've both got US citizenship. To get HK residency as well as US citizenship, our kids would have to be born in HK. We don't actively live in HK, and your anecdotes are making me wonder how feasible this would actually be within the time frame of maternity leave.
The CBP immigration officer made an exception under the premise that we would expediently apply for the US passport at a local agency during our visit. We were grateful, because of course he could also have sent us back home...
It's the opposite. Most countries don't have an opinion on other citizenships. A minority disallow you from having another, sometimes only after the 2nd. An even smaller minority require you to relinquish any other citizenships when gaining theirs.
It seems to work out with this set of countries. Croatia lets you keep other citizenships if you claim the Croatian one via jus sanguinius. German citizenship is compatible with other EU/Swiss citizenships and citizenships acquired at birth. The US and Switzerland don't care that much. In practice, such webs of multiple citizenships can become tricky if one of the countries involved has mandatory draft, but it seems you can avoid the Swiss draft if you don't live there. Finally, I don't see why there would be a need to inform these countries about additional citizenships, unless they mandate it by law.
> it seems you can avoid the Swiss draft if you don't live there

I think you can apply for an exemption especially if were already subject to the military draft of your country of origin. You might also be exempt if you just gain citizenship after a certain age.

It should be more legal if anything. The problem are countries like Japan/China/Korea which prevent you from holding any other citizenship at all. "Don't tell" is not really an option - if they find out they'll tear up your citizenship which can leave you with a big problem if you are living there or ever want to visit.
That’s wrong in the Japan case. Japan permits its citizens to hold both nationalities when the second one is acquired at birth. Moreover the government doesn’t hunt them in any way. Sources: multiple half-Japanese friends + the web.
> Most countries in the world disallow holding more than 2 citizenships.

Do you happen to have a reference to back this up?

Why would they need to be informed?