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Yong Troy
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W%o Chims Dual Citizensh+? The Limits of Postnationalism, the Possibilities of Transnationalism, and the Persistence of Traditionul Ciitizensh+' IrenBloemraad UniversiofCalifornia,Berkeley The dynamics of lobalization, especiallyinternational migration, chal- develo new modelsof membership: transnationalism and postnational- ism.Al tree- the traditional, transnational and postn-explic- itly or implicitly address the controversial to ic of dual citizenship, or multiple membership. LaofstatisticaldaRowever,has made it dis- cult to adjudicate between these models orrtakeabroad empiri- calassessmenof dual citizenship, either over time or between people from different countries and socioeconomic backgrounds. This article outlines the testable implications of traditional, transnational and post- national frameworks and evaluatesthese hypotheses using a unique sta- tistical data source that asked respondents multiple citize,shi the 1981, 1991 and 1996 20% Canadian census samples.The d2er o little evidence that immigrants adopt a strict postnatofnciti-ew zenshi,but they revealthe possibioftransnationalism and the con- tinu{ relevanceof traditional frameworks.Over time, weobservea rapid increasein the aggre ate levelorted dual citizenship from 1981 to 1996. We alsofindaat those with higher human capital,rather than the economically marginalized, are more likely to embrace dual citizenship. After controlling for individual attributes, important contextual or group effects nonetheless remain: self-reports citizenship vary signifi- cantlyby birthplace and arehigher ifan immigrant livesin Quebec. Since naturalization levelsstorise in tandem with reports of dual citizen- ship, this research suggeststain paradox: while multiple belonging 'This project was bythe National Science Fo(SES-0000310the Weather- head Center for International Affairs, Harvard University and ofatistics Canada, Division Housing, Familyand SocialStatistics.The author would like to thank AlexAeinikoff, Bayliss Camp, Kathleen Coll, Andy Karsh, ZiaPeggyLevitt, Jeff Reitz, tof reviewers this journal and members of the Harvard Immigration Workson earliermments drafts. My sincere thanks also to Doug Norris and Jane Badetsda for pro- SociologicalAssociation, CA,August 2001.a. A previousatthe Americanesented 0 200bytheCentfoMigratiStudieNewYork.Ailrightsreserved 0197-83/04/3802.0146 IMR Volume38 Number2 (Summer2004):389-426 389 390 INTERNATION MAILRATIO RNEVIEW undermines some aspects of conventional state sovereignty, dual citizen- ship might be a means for countries to promote immigrants’politicaland legal attachments. Citizenship has long been considered a progressive force within nation-states. The desire for full citizenship has animated struggles by the working class (Marshall, 1950), women (Bredbrenner, 1998) and ethnoracial minorities (Smith, 1997) seeking the same rights and legal status as their compatriots. Yet, a growing number of scholars suggest that traditional citizenship is fun- damentally illiberal in today’sglobal world (Carens, 1987; Baubock, 1994; Stasiulis,1997). According to Carens, citizenship in Western liberal democ- racies is “the modern equivalent of feudal privilege- an inherited status that greatly enhances one’slife chances” (1987:252). Older notions ofstate sover- eignty butt against advances in communication and transportation, the spread of international norms, a global economy and, in particular, substan- tial international migration. The consequences of globalization have led scholars to advance new approaches to citizenship, theories of transnational belonging (Basch, Glick Schiller and Szanton Blanc, 1994; Portes, Guarnizo and Landolt, 1999) and postnational membership (Soysal, 1994; Jacobson, 1996). In these debates, dual citizenship holds a prominent place. Traditionally, nation-states have frowned upon dual citizenship since it undermines the single and exclusive link between an individual and a sover- eign nation-state. Reservations include split loyalties, dual military service, double taxation and conflicting diplomatic protection (Hammar, 1985). Stu- dents of transnationalism claim that the multiple belongings inherent in the contemporary world demand dual citizenship. Migrants’, and, increasingly, countries’, desire for multiple citizenship creates new ‘deterritorialized’ nation-states (Basch, Glick Schiller and Szanton Blanc, 1994). For scholars of postnationalism, the critique goes further: over the long-term, citizenship will cease to be relevant as rights increasingly are invested in the person, not in a legal relationship between individuals and the state. Dual citizenship can, at best, be an interim trend. Adjudication betweenthese different models has been difficult. There is a rich theoretical literature on dual citizenship (Hammar, 1990; Schuck, 1998; deinikoff and Klusmeyer, 2000) and burgeoning research on states’ decisionmaking on dual nationality (Guarnizo, 1998; Jones-Correa, 200I).* 2Largelyfor stylistic reaIuse the terms “dual citizenship” and “dual nationality” inter- changeably.The data presented here come from individuals’self-reportedstatus; it whether respondents would make a distinction between these two terms. WHO CLAIMS DUAL CITIZENSHIP? 391 Yetweknow little about dual citizenship among ordinary people:who claims dual citizenship? How do individuals' claims vary by country of origin or socioeconomic background? Has support for dual citizenship changed over time? As a number ofscholarspoint out, researchershave beenunable to pro- vide accurate statistics or analysesof dual citizenship for want of adequate data (Hammar, 1985; Spiro, 1997; Aleinikoff, 1998). Using self-reportedcensusdata from immigrants in Canada, this article aims for a broad empiricaloverviewand analysisof dual citizenship,assessing the data's implications for the traditional, transnational and postnational frameworks of citizenship.3The bulk of the literature on transnationalism relies on case studies of immigrants living in the United States, especially those from Latin America and the Caribbean. The research methodology is frequently ethnographic or basedon detailed qualitative interviewswith arel- atively small number of respondents. In contrast, most claims for postna- tional membership use data from Europe, particularly the member countries of the European Union. Evidence comesfrom government documents, legal decisions, international agreements and interviewswith government officials and leaders of community organizations. Differences in research sites and methodologies might go far in explaining why scholarshave produced diver- gent responses to the challenge of globalization on traditional citizenship regimes. Here Iemploy a unique data source, the Canadian census 20% micro- filesfrom 1981, 1991and 1996. In all three enumerations, members in one in fivehouseholds wereaskedtheir citizenship and encouraged to report mul- tiple nationalities. Canada provides an ideal context to study dual citizenship sinceit possessesmany characteristicsidentified byscholarsof allthree frame- works: Canada encourages naturalization, in accordance with traditional models; it officiallyacceptsdual citizenship, central to transnational belong- ing; and it makes almost no distinction between noncitizen permanent resi- dents and naturalized Canadian citizens, a key feature of postnational theo- rizing. First,I reviewtraditional, transnational and postnational models, draw- ing out each framework'spropositions regarding dual citizenship. Second, I 3Nonimmigrants can alsohold dual citizenship through marriage to a foreign nbyional or descent from an immigrant parent or grandparent. Indeed, growing numbers of the native born are expressinginterest in dual nat-oin North America, individuals oken tosh gain accessto the European Union (:ortese, 2001). In a very few cases,individuals with largecapital assetscan buy a foreign nationality.The focushere, however,ison immigrantdual citizens. 392 INTERNATION AIGRATIO RNVIEW introduce the Canadian censusdata and examine aggregatetrends in dual cit- izenship from 1981 to 1996. I pay particular attention to change over time and differences between immigrant groups. In the third section, I focus on variation in individuals’propensity to identify as dual citizens. Using logistic regression,I model an immigrant’sprobability of reporting dual citizenship giventhe independent variablessuggested bythe three theories of citizenship. The conclusion summarizes the main findings, discussesthe implications of these findings, and offerssuggestionsfor future research. To anticipate those conclusions somewhat, the evidence demonstrates the continued relevanceof traditional approaches to citizenship, the limits of postnationalism, and the growing possibilities of transnationalism. Immi- grants are eagero naturalize and embrace Canadian citizenship, but they are also increasingly likelyto retain their nationalityorigin. At an aggregate level,only a smallminority reports dual citizenship, but within certain immi- grant groups this minority can be substantial. The propensity for dual citi- zenship appears negativelylinked to indicators of host country integration: claimsofmultiple nationality decrease overtime, are lowerfor child migrants, and are higher for immigrants who speak ahousehold language other than English or French. The dual national appears to be someone who is highly educated and mobile with relativelyfew family ties. Dual citizenship might consequently be the purview of an educated globalelite, although there isevi- dence that the desireto identify as a dual citizen is rapidly diffusing within certain immigrant groups. CITIZENSHIEIMMIGRATION AND THE CHALLENGE OFGLOBALIZATION TheTraditionaM l odel:Citizenshipin Sovereign Nution-States During the nineteenth century, the notion that the apparatusofgovernment - the state- should overlap and be congruent with a community ofidentity - the nation- gained prominence (Hobsbawm, 1992; Anderson, 1991).Cit- izenship provides legal standing and rights from the stateand it signals belonging to asubjective nation. Brubaker (1990) proposes that the ideal- typical model of traditional citizenship suggeststhat membership is egalitari- an, sacred, national, democratic, unique and socially consequential. When immigrants move from one country to another, they complicate the link between the citizen and the nation-state. Since countries can only exert sov- ereignty over the inhabitants of their bounded territories, traditional approaches assume that immigrants gradually losetheir attachment to the WHO CLAIMS DUAL CITIZENSHIP? 393 sendingcountry, then ‘naturalize’byadopting the citizenshipof the receiving country. To a large extent, this process is an “eitherfor”proposition: either you are a citizen of your home country or you adopt the nationality of the host country. In this context, dual citizenship inhabita curious place. On one hand, it undermines traditional citizenship by allowing,and even promoting, mul- tiple belonging, claims-making, rights and responsibilities. Given that citi- zenshipinvolvesa certain sacralizationof socialand political membership, ties should be unique, not multiple (Brubaker, 1990). Opponents of dual citi- zenship, and even somesupporters,worry that dual nationals might lack suf- ficient loyaltyto their new country or undermine the state’spolitical interests (Renshon,2001; Schuck, 1998:244-246). On the other hand, dual national- ity reinforces the centrality of nation-states because they continue to be the bodies that grant citizenship. Somearguethat dual nationality can reduce the “in-betweenness”immigrants feelby encouraging them to naturalize, become politically active, and integrate further into the host society (Jones-Correa, 1998). Rather than lessloyaland committed, dual citizenshipmight increase an individual’sties to the nation-state. Those who support a traditional model of citizenship recognize the challenges that globalization poses for nation-state sovereignty.Some accept the need for limited dual nationality, usually asa means to encourage incor- poration in the host country. It is implied, however, that the former citizen- ship becomes lesssalient over time and might be dropped altogether. In this respect, nation-states continue to exhibit political relevanceand exert strong forcesof socialization:“[tlhosewho herald the emergingpostnational age are too hasty in condemning the nation-state to the dustbin of history” since cit- izenshipcontinues to be “apowerful instrument of socialclosure”(Brubaker, 1992189, x; Koopmans and Statham, 1999). What does a traditional approach to citizenshipimply for dual nation- ality? First, we should find high levelsof naturalization among immigrants and relatively few claims ofdual citizenship. Most people will recognizethe need to adopt one primary identity and political loyaltyand they will trans- fer their subjectiveand objective attachments to their new home. Second, if some immigrants initially identify as dual nationals, over time they should increasingly favor the unique citizenship of the receiving country. Finally, those who claim multiple citizenship will be the least integrated in the host country. With integration, immigrants should embrace a single membership status. 394 INTERNATIONM ALIGRATIROENVIEW Transnationalism D:eterritorializedCitizenship For scholars of transnationalism, dual citizenship recognizesthat immigrants’ livestranscend borders.Transnational researchersconceptualize adeterritorial- ized nation-state where “immigrants forge and sustain multi-stranded social relations that link together their societiesof origin and settlement” and “in which the nation’speoplemayliveanywherein the world and stillnot liveout- sidethe state” (Basch,Glick Schillerand Szanton Blanc, 1994:7,269). World capitalismis often fingeredasa driving force of change (Basch,Glick Schiller and Szanton Blanc, 1994; Portes, Guarnizo and Landolt, 1999). Due to the core-peripherystructure of the international economic system,migrants from developingcountries are forced to find employment in the developed world. Once there, they frequently hold jobs in secondary markets, either in low- skilledmanufacturing or poorlypaid servicepositions. Atthe peripheries ofthe labor market, these immigrants feel marginalized from the host society,and they simultaneously retainlinksto the sending country through remittancesor entrepreneurial activities.Ironically,while many are forcedto migrate due to globalcapitalism, somesubsequentlyengagein transnational economic activi- ties themselves. Economic marginalization is frequently aggravatedby racialand ethnic alienation (Basch, Glick Schiller and Szanton Blanc, 13949, 30-45; Portes, Guarnizo and Landolt, 1999:228-229). For example,nonwhite immigrants to the United States might feel ambivalent about their place in American racial categorizations and challenge designations such as “African-American”or “black” by affirming homeland nationalities as“ethnic” identities (Waters, 1994).Yet,since their dailylivesare shaped byAmerican paradigms,they also internalizeand transfer Americansocialnorms to relativesand friends in the sendingcountry (Levitt, 1998). Consequently,immigrants both challengeand transfercultural idioms acrossgeographicalspace(Vertovec,1999:450-452). Within these structuring dynamics - global capitalismand ethnoracial hierarchies- immigrants create transnational livesthrough “occupationsand activities that require regular and sustained social contacts over time [and] acrossnational borders for their implementation” (Portes,Guarnizo and Lan- dolt, 1999:219). Dual citizenshipis both a causeand an effectof transnation- alism.Dual citizenship can facilitatetransnationalis- multiple passports pro- videeasy access toand rights in differentgeopoliticalspaces- and it designates dual identities, reflectingattachment to both sending and receivingcountries. Immigrants often lobby for dual nationality laws to reflect these multiple attachmentswhilecountriesoforigin,and somecountriesof reception,encour- WHO CLAIMS DUAL CITIZENSHIP? 395 age dual nationality to further state interests (Jones-Correa,2001; Guarnizo, 2001; Portes, 1999:466-468). Many developing countries, in particular, are moving from a traditional notion of bounded, sovereignstates to a deterritori- alizedvision ofmembership (Basch,Glick Schillerand Szanton Blanc, 1994). The transnational approachhas clearimplicationsfordual citizenship. It suggeststhat where dual citizenshipis possible,large numbers of immigrants will embrace this status to reflect multiple identities and transnational lives. Second, asglobalizationexpands, dual citizenship should increaseover time. While proponents of transnationalismrecognize thatmigrantshavelongforged cross-nationallinks between sending and receivingcountries, they argue that “earlytransnational economic and political enterpriseswere not normative or even common among the vast majority of immigrants, nor were they under- girded by the thick web of regularinstantaneouscommunicationand easyper- sonal travel” of today (Portes, Guarnizo and Landolt, 1999:227; Vertovec, 1999;for adissentingargument, seeFoner,1997).Third, iftheworld isincreas- inglytransnational,eachsuccessivecohort of immigrantswillbe more likelyto claim dualcitizenship. Scholars oftransnationalism are only now beginning tohypothesizethe waysin which transnational activityand belonging change over the course of an immigrant’slifeor vary between individuals.Nancy Foner (1997) cautions that the transnational impulse might diminish with time, while PeggyLevitt (2003) speculatesthat ties and activitiescan vary overthe lifecourse.There isa potential overlapwith hypothesesfrom traditional frameworks:the bulk of the transnationalismliteraturesuggeststhat the lessrootedan immigrant,the more likelyhe or shewillidentitjrasadualnational (butseeMorawska,2003 on why assimilationand transnationalismmight be complementary). In contrast, explaining variation between individuals raises somewhat contradictory hypotheses. One strand of transnationalism suggeststhat poor, nonwhite immigrants from developing countries are particularly apt to lead transnational livesand favordual citizenship.These individualsuse cross-bor- der activities and multiple identitiesto challenge their marginal racial, eco- nomic and socialpositions in the receivingcountry (Basch,Glick Schillerand Szanton Blanc, 1994). Sincemost contemporary transnationalism scholarship relieson casestudies of Caribbean and Latino immigrants,we haveno data to indicatewhether contemporaryEuropean immigrants leadsimilartransnation- allives. Wethereforedo not know whether dual citizenshipismore of aThird World or FirstWorld phenomenon. 396 INTERNATION MAILRATIO REVIEW Other students of transnationalism posit that the possession of skills and resourcesencourages transnationalism and dual citizenship.Those with “greateraverageeconomic resourcesand human capital (education and pro- fessional skills)should register higher levelsof transnationalism because of their superior accessto the infrastructure that makes these activitiespossible” (Portes,Guarnizo and Landolt, 1999:224). Among New York‘sIndian com- munity, Lessinger (1995) found the most transnational immigrants to be successfulprofessionals and business people (seealsoOng’s (1999) study of Chinese migrants). Consequently, we might expect that immigrants able to buy,use and benefit from the technologiesnecessaryfor transnationalism are more likely to be dual citizens. Socioeconomic advantage, not marginality, would be critical to explainingdual citizenship claims. PostnationaC litizenship- BeyondtheNation-State Theories ofpostnationalism challenge the very idea that citizenship remains linkedwith statemembership,be it territorializedr not. Proponents arguethat the advantagesofcitizenship,suchascivilrightsand socialwelfare, are increas- inglyvestedin individuals- or ‘personhood’- ratherthan through membership in a nation-state (Baubock, 1994; Soysal,1994;Jacobson, 1996). This occurs because“in North AmericaandWestern Europe, the basisofstatelegitimacyis shiftingfrom principlesof sovereigntyand national self-determinationto inter- national human rights”(Jacobson, 1996:2). Divergingfrom transnationalism’s focus on global capitalismand racialhierarchies,the postnational perspective emphasizesthe influence ofinternational moral and legalnorms. Accordingto postnational scholars,human rights undermine traditional notionsof citizenshipdue totheir power asan acceptednormative framework and through their institutionalization.Asa normative resource,human rights providemigrantswith a discourseto make claimsregardlessof citizenshipsta- tus. Politiciansand policymakers“find it much harderto deny socialand civil rights- those directlylinked to the person, such asindividual libertiesand a minimum standard of living - to new groups of people, even ifthey do not belong to the formal national polity” (Soysal,1994:131). When these norms become institutionalized in supranational organizations like the European Union (Soysal,1994),codifiedin international law (Jacobson,1996), or prop- agated by international social movements (Risse, 2OOO), they become even more powerful. The implications of postnationalism for dual citizenship are implicit rather than explicit.The logicof the theory suggeststhat immigrantswillshun WHO CLAIMS DUAL CITIZENSHIP? 397 the receivingcountry’scitizenshipaltogether. Securein the knowledgethat their rights are guaranteed based on personhood and that their identities transcend the trappings of citizenship,one would expectimmigrants to not naturalizeat all,retainingthe nationalityofthehomecountry byfiat. Suchahypothesisruns in direct contradiction to traditional notions of immigrant integration, where home country nationality is abandoned in favorof host country citizenship.I callthis argument “strictpostnationalism.”In reality,many proponents of post- national citizenshipfailto go so far,although somehint at the possibility(e.g., SOYS~1 ,994:26-27). More often, those who identifyan emergingpostnational systemsuggest that the short-term resultfglobalizationwill be increased claimsof dual citi- zenship. Eventually,residencewill determine legalstatus and state-bound citi- zenship will wither away,but, during the interim, states continue to play an important role.I label this strand “weakpostnationalism.”Like transnational- ism, aweakpostnational perspectivehypothesizessignificantlevelsof dual citi- zenshipwhereit ispermitted. In contrast, the postnational model suggeststhat claims ofdual citizenshipshould decrease overtime. The literatureon postnational membershipdoesnot specifywho ismost likelytoembracedual nationality.Advocatesimplythat the languageofhuman rights is so stronglydifhsed thatallgroups are equallyaware of this resource (Soysal,1994: 154-15 5).If differencesexist,they relateto the type of receiving society.Establishedliberal democraciesinWestern Europe, North Americaand Oceania will be more sensitiveto human rights appealsthan fledgling states. Extending this logic, it is possiblethat immigrants from Western Europe are more postnational - and thus lesslikelyto naturalizeor claimdual citizenship - sincethey aremore cognizantof human rightsdiscourses. In short, the traditional, transnational and postnational approachesoffer quite differenthypothesesconcerningthe prevalenceof dual citizenshipamong immigrants.Table 1 summarizesthe implications ofallthree perspectives.The next sectionbeginsto evaluatethese hypotheses. First, introducethe Canadi- an censusdata, and then I outline trends in naturalizationand dual citizenship overtime and acrossgroups. DUAL CITIZENSHIPACROSSTIMEAND BETWEEN GROUPS: EVALUATINGTRENDS Immigration to Canadzand theCanadianCensus In 1997, Peter Spiro lamented, “Statistical surveys of the number of dual 398 INTERNATION MAILRATIO REVIEW TABLE 1 THREM E ODEL OF cll”SHIP: IMPLICATIONSFOR DUALCITIZF.NSHIP TraditionalModel TransnationalModel PostnationalModel TheoreticalClaim Eachpersonhas a single Immigrants’livesspan Normativechanges citizenshipthat linksthe geopolitical borders, valorizipersonhood individual to a nation-stacreatingtransnational are eclipsingstate- activitiesand identitiescenteredcitizenship Rights and identity are Citizenshipcan be Rightsdo not depend congruent with citizenship.ultiple; memberships on citizenship;identities arein deterritorialized transcend nation-states. nation-states. Implications Immigrantswillnaturalize; Significantnumbersof Strictview:immigrants for Dual fewwill claimdual immigrantswilladopt willretain homeland Citizenship citizenship. dual citizenship. citizenship; weakview: possibledual Citizenship. Over time, peoplewho Levelsof dual citizenshiDual citizenshipwill initiallyasserteddual willincreaseovertime decreaseovertimeas citizenshipwillonlydaim as more countriesallow human rights norms the receivingcountry it and more peoplewant diffuseand take root. citizenship. multiple memberships. Potential Poorlyintegrated The marginalized(poor, Immigrants from theU, Individual immigrants (thosewho racialminoritiesfrom moreexposedto human Variationin Dual arenot ‘rooted’in the developingcountries) rightsdiscourses,will Citizenship receiving society) willidentifasdual naturalizlesand be aremore likelyto have nationals;R business lesslikelyto claimdual dual citizenship. people, thosewith citizenship. higher education and income are morelikely to embracedual citizenshin. nationals appear never to have been undertaken, nor have the United States or other governments sought to collect such information” (1 997: 1455). While Spiro is correct about the dearth of statistical scholarship and general lack of such data, he overlooks one critical source of information on multiple nationality: the Canadian Census of Population, held every five years. Since 1981, Canadian residents have been repeatedly asked to report their citizen- ship and explicitly directed to give multiple answers. The bulk of research on transnationalism and postnationalism relies on qualitative evidence collected from ethnography,in-depth interviews,government documents and interna- tional law. The richness of this data comes at the expense of understanding howfar-reaching the phenomenon ofdual citizenship really is. Is dual nation- ality mostly found among a few immigrant communities and some isolated individuals, or are broad groups of people embracingmultiple attachments? To answer this question and evaluate the argumentsoutlined in Table 1, I analyze immigrants’ self-reports ofdual citizenshipusing the full20 percent microfile samplefrom the 1981, 1991and 1996 Canadian censuses. The 20 WHO CLAIMS DUAL CITIZENSHIP? 399 percent sampleincludes allrespondents who answeredthe “longform” of the census (1 in 5 households). In 1981 and 1991, respondents were presented with four closed-endedcitizenship choices:Canada by birth, Canada by nat- uralization, same asthe country of birth (other than Canada), and another country. Allowing for multiple answers,an individual could fallinto one of nine different citizenship categories;immigrants could conceivablyfall into one of seven.4The 1996 question variedslightly,givingthe options “Canada, by birth” and “Canada, by naturalization,” then it provided spacefor respon- dents to write in other countries of citizenship, if applicable. For the analysis that follows,I drew a sample of all foreign-born adults who were permanent residents or naturalized Canadian citizens.5The resulting dataset contains 1,025,109 respondents in 1996, 783,911 individuals in 1991, and 645,157 in 1981. In contrast to the 3% Public Use Microfile sample releasedby Sta- tistics Canada, these data permit a detailed analysisof dual citizenship. It is important to emphasize that the citizenship question measures reported citizenship status.While in many caseswe can assume that respon- dents’ reported citizenship corresponds to their actual legalstatus, this is not necessarilythe case.First, immigrants might professto be dual citizenseven if their former country does not allowmultiple nationalities.The legalcodes of variouscountries,suchasIndiaand the Netherlands,specifythat naturalization in another nation-state resultsin the automatic lossof one‘sformer citizenship. In such a case, an immigrant‘sclaim of dual nationality is either a function of poor information or a statementof dual identity despitelegalstatute. Second, immigrants might be de jure dual nationals but not recognize or acknowledgethis fact. A growing number of states explicitlydeclarethat cit- izenswho naturalizein another country do not lose their former citizenship. For example, Portugal made this change in 1981 and El Salvador did the same in 1983. Anyone from these countrieswho became a naturalized Cana- dian after the law changed would be a legal dual national. Those failing to *The nine possibilitiesare 1) Canadian by birth, 2) Canadian by birth and citizen of another country, 3) naturalized Canadi4),naturalized Canadian and citizen of birth cou5)ry, naturalized Canadian and citizen of another country (not country of6)inaturalized Canadian, citizenfbirth country and citizen of another country, 7ofcbirth country, 8) citizeofbirth country and another coun9)ycitizen of another country (not cooftry birth). Xxcluded are those who are foreign born but receivedCanadian citizenship at birth through their parents.so excluded are foreign-born adults who, at tofthe census,were non- immigrant resident(.g.t,ey held a student visa or refugee status). Those who were perrna- nent residentsat the time of the census but previouslyheld nonresident visasor refugeestatus are included. 400 INTERNATIONALMIGRATIO REVIEW report their objectivestatusmight do so becausethey do not realizeor do not wish to acknowledgedual citizenship. These contradictory tendencies introduce a certain levelofambiguityto the interpretation of census statistics, but self-reported data offer distinct advantages.Both transnational and postnational frameworks claim that sub- jective identities and lived experiencetrump legalconstructs dividing people into geographically bounded nation-states. To the extent that people claim dual citizenshipdespite legalinterdictions,e find support for these perspec- tives. In contrast, if immigrants who are dejzrre dual citizens fail to report such status on the census (an instrument aimed at elicitingfactual informa- tion), traditional notions of citizenship gain credence. Like researchon eth- nic identity, the disjuncture between objective and reported status reveals much about individuals’identities and sense of place in a larger socialstruc- ture (Waters, 1994; Boyd, 1999). The limit of census data, however,is that we know little about the content of such identities. Beyond the unique statistical opportunity offered by Canadian census data, the Canadian case provides a number of theoretical advantages when testing citizenship paradigms. Canada shares many key characteristics with Western Europe and the United States, the sites where postnational and transnational theories were developed.First, likthe United States,Canada is a longstanding country of immigration.Today about 19 percent ofthe Cana- dian population is foreign born, a percentage that has increased gradually from 15 percent immediately after World War 11.Prior to 1962, migration drewheavilyfrom European countries becauseimmigration regulationsmade it difficultfor non-Europeans to gain entry. Sincethen, Canada attracts indi- viduals from around the world. In 1996, 31 percent of the more than 4,971,000 immigrants living in Canada were born in Asia and 6 percent hailed from the Caribbean. Considering only migrants with fifteen years of residence or lessfullyhalfwereborn in Asia. Sincesometransnational schol- ars maintain that nonwhite immigrants from developingcountries arepartic- ularly apt tolead transnational livesand adopt dual citizenship, the Canadi- an context allowsus to test such claims. Second, as in Western Europe, Canada providesa broad range of social benefitsto its residents,regardlessof citizenshipstatus. Immigrants receivethe same health care coverage,unemployment insurance and welfare benefits as Canadian citizens.In contrast, the United States reinforcedthe link between citizenshipand socialrightsin 1996 by denyingwelfarebenefits to noncitizens, even ifthey are legalresidents.Although it isdifficult to make the postnation- WHO CIAlMS DUAL CITIZENSHIP? 401 al argument in the American case, it is plausible in the Canadian one. Con- versely,like the United States,Canada seesitself asa country of immigration and administers a liberaland relativelyopen naturalizationpolicy.6Traditional patterns of citizenship are consequently more plausible in Canada than in Europe. Finally,unlike the United Statesor many European countries,asof 1977 Canada has explicitly alloweddual citizenship.Indeed, to a certain extent the government promotes this option asa symbol of Canadian toleranceand asa reflectionof its multicultural society.If dual citizenshipis rampant, we should find many dual nationals in Canada. Traditional, transnational and postna- tional models are equally plausiblein the Canadian case,allowing thesetheo- riesto be tested fairly. Naturalization:TheLimits of Postnationalism andPersistence of Traditionalism According to a strict reading of postnationalism, we should expect low levels of dual citizenship because immigrants will not naturalize. In countries such as Canada, rights traditionally associatedwith legalcitizenshiparegiven to all immigrants. For example, provincial governments provide Medicare benefits and welfarepayments to all eligibleresidents, regardlessof citizenshipstatus. Consequently, migrants face no need to acquire Canadian citizenship for socioeconomic benefits.7Yet, in 1996, 75 percent of all adult immigrants claimedCanadian citizenship through naturalization. In 199 I, this figurewas 73 percent, and in 1981, it was 72 percent. Naturalization figuresin Canada consequently support traditional notions ofcitizenship: a substantial majori- ty of immigrants continues to acquirecitizenship in their new country.*Nat- uralization levelsare even more striking once we excludethose ineligible for naturalization becausethey have not yet met the three-year residencyrequire- ment. Considering only eligibleadult immigrants, fully 84 percent were nat- 6Immigrants to Canada generally need only three years of residence, some English or French language skillsand a basic knowlofthe country to acquireCanadian citizenship. 'The major rights that citizenship accordsisthe absoluteright of entry onto Canadian soiland political rights such as the right to vote and run for ofice. 81ncomparison,35.1 percent of tU.S.foreign born had acquired American citizenship in age naturalization rate in the core European Union and European FreeTrade Area countries is about 2 percent. This rate - calculated asthe annual number of naturalizations over the noncitizen foreign 'stock'ged widely across Europe in the 1990s,from lessthan 1 percent in Germany Ireland, Italyand Switzerl6.5percent in the Netherlands and Swe- den. Reproducingthis calculationin North America, we find a naturalization rate percent in the United States and 10 percent in Canada over the same period. 402 INTERNATION MAILRATIO REVIEW uralized in 1996,82 percent in 199 1 and 77 percent in 1981.These high lev- elsof naturalization suggest that key propositions of strict postnationalism are incorrect. Scholars ofpostnationalism might respond that aggregate naturalization levels are not a fair test since the theory rests on recent changes in the world system. The importance of human rights has grown during the post-World War I1 era. Older immigrants came at a time when naturalization was still important; only recent immigrants face a postnational age where citizenship acquisition ceases to matter. Yet, as Figure I demonstrates, immigrants' propensity to naturalize has increased over time, casting doubt on a strict ver- sion of postnationalism. Figure I plots naturalization levels by length of resi- dence in Canada for the three census years under consideration. The trend lines clearly show that immigrants migrating later in the twentieth century become Canadian citizens more quickly than the comparable cohort a census earlier.Ifwe consider immigrants who have lived in Canada for eleven to fif- teen years, 83 percent were naturalized in 1996,78 percent had taken Cana- dian citizenship in 1991,and 68 percent were Canadian in 198 l. Itis possi- ble that low levels of naturalization in Europe - the source of most evidence for the postnational perspective - are less a function of postnationalism than onerous citizenship laws and naturalization regulations (Clarke, van Dam and Gooster, 1998; de Rham, 1990). FigureI. Percentof Adul tmmigrantsNaturalized,byLength of Residence, 1981,1991 and1996 Canadian Census 100 80 80 70 c p" -5 4 +- e40 !? 30 20 10 0 0 5 10 15 m 25 Percentof Resident WHO CLAIMS DUAL CITIZENSHIP? 403 The postnationalist argument also implies that conceptions of postna- tional membership should be more prevalent among immigrants from the member states of the European Union. These people are most likely to be aware of norms that favor personhood over nation-state membership since they migrate from stable liberal democracies. Evidence for this hypothesis is mixed. Table2 breaks down naturaliza- tion levels by birthplace for twenty countries in 1991. The first column reports the aggregatenaturalization level forlladult immigrants who have met the three-year residency requirement. The second and third columns report naturalization levelsfor recent cohorts, those who migrated in the peri- od of postnationalism identified by Soysaland Jacobson. We find that while some EU nationals appear slightlyslowerto adopt Canadian citizenship than immigrants from other countries, the majority do so within eleven yearsof residence and, in some cases,after only six to eight years in Canada. Those least likely to acquire Canadian citizenship are Americans, not Europeans. After eleven to fifteen years in Canada, only39.7 percent of the American born had naturalized. Dutch immigrants have the second lowestlevel ofnat- uralizationat 49.6 percent, while the Portuguese are third at57.5 percent. Those hailing from France, a member of the EU since its inception, hava level of naturalization that, at 86.7 percent, is higher than Mexicans, Jamaicans, Indians and Salvadorans. Some Europeans might hold postna- tional views,but the evidenceisnot overwhelming.Traditional notions of cit- izenshipappear reinforcedsince,with fewexceptions,naturalization levelsare high regardlessof origin. Dual Citizenship:The Possibilitiesf Transnationalism If immigrants do not shun Canadian citizenship, asa strict postnational model would suggest, they might instead inhabit a transnational world and embrace dual citizenship. Scholars of transnationalismdo not specifya level of dual citizenship that would clearly undermine the traditional paradigm. Does proof of significant transnationalism require thata quarter, a third or even half of naturalized Canadian immigrants claim dual citizenship? To investigate the level and determinants of dual citizenship,I consider only those immigrants who have acquired Canadian citizenship through natural- ization and divide them into two categories,those claiming a single citizen- ship status (Canadian) and those reporting more than one nationality. All multiple citizenshippermutations are collapsedinto one ‘dualcitizen’catego- ry,even ifthe person is, in effeca,citizen of more thantwo countries. 404 INTERNATIONALMIGRATION REVIEW NATURALIZ~T IONEE3 OF ADULT IMMIGRANTS,BYck”TRY OFBIRTH AND LENGT OHF RESIDENCE1991 CANADIAN CENSUS Alleligible Lengthof Residencein Canada Placeof Birth immigrants 6-8yrs. 11-15yrs. SampleN Europe France 88.0 73.9 86.7 10,269 Greece 88.0 72.5 81.0 15,646 Netherlands 87.0 32.1 49.6 25,182 Germany 83.1 41.6 60.9 35,221 Italy 82.2 59.2 68.7 67,127 UK 81.9 56.4 69.3 136,387 Ireland 79.3 45.7 69.7 5,254 Portugal 65.6 44.7 57.5 28,600 North America Mexico 81.4 72.1 79.3 2,957 USA 55.0 30.9 39.7 48,038 Caribbeanand Latin America Haiti 89.3 92.1 93.5 6,719 Guyana 86.1 78.7 90.0 11,538 Jamaica 81.1 58.8 81.2 17,876 El Salvador 63.8 69.3 81.2 3,931 Asia China (PRC) 88.5 84.0 89.8 29,253 Philippines 87.1 81.4 91.3 21,465 Pakistan 85.5 75.1 87.3 4,342 Lebanon 85.4 86.0 88.0 8,871 Vietnam 84.6 83.0 88.3 18,211 India 73.1 53.4 72.2 31,737 Over time, we find rapidly increasing levels of dual citizenship,though only among a minority of naturalizedimmigrants. Table 3 calculatesdual cit- izenship for various age groups. Considering all naturalized immigrants in Canada, 5.5 percent claim dual citizenship in 1981, 10.7percent report dual nationality in 1991, and 16.6 percent do so in 1996.9Canada began permit- ting dual citizenship in 1977, so it is not surprising that reports of dual nationality in 1981 are relativelylow. The increase over time is substantial. From 1981to 1991,claims of dual citizenshipalmostdouble, and from 1991 to 1996 they increaseanother 50 percent. The sharp rise appears suggestive, although the figuresin Table 3 show that dual citizenship is prevalent among only a minority of immigrants. 9As a percentof all immigrants (including non-Canadian citizens), 12.1 perofnallimmi- grants claimed dual citizenship 1996, 8.2 percent in 1991 and3.9percent in1981. These figures include a small fractionpeople reporting dual nationality in which Canada is not one of the countries of citizenship. WHO CLAIMS DUAL CITIZENSHIP? 405 CLAIMSOFDUAL CInZENSHIPBYNATURALIZ CA ” bfMIGRANTS, 1981. 1991AND 1996CANADIAC NENSU(S201 SAMPLE) Population 1981 1991 1996 Immigrantsofallages 5.5% 10.7% 16.6% Immigrant adults 5.1 10.4 16.1 Immigrant children 11.8 19.8 25.2 Immigrantsho moved toCanadaasadults 6.1 11.2 17.8 Immigrantwho moved toCanadaaschildren 4.6 9.9 14.3 TheUniqueCase ofImmigrantChildren Children occupy a unique status under citizenship law,in the statutes of the receivingcountry and often in the legalcode of the sending country. Under Canadian law, individuals under the age of 18 cannot naturalize indepen- dently. To become aCanadian citizen, the parent of an immigrant childmust naturalizeand indicate that he or shealsowishesto naturalize his or her child. For the sendingcountry,child naturalization isnot alwaysviewedin the same light asthe naturalization of an adult national. Even when an adult loseshis or her former nationality by acquiringCanadian citizenship,children can fall into three categories.In some cases,children alsoautomatically losetheir for- mer citizenship (e.g.,citizens of India). In others, the child continueto be a dual national until the age of majority at which time he or she must chose one citizenship (this used to be the case for American emigrants). Finally, some countries do not recognizechild naturalization, since the child had no independent choice in the matter. These states continue to view the individ- ual as their citizen, evenafter the child reachesthe agof majority (such isthe caseunder Dutch law). To get a senseof how age matters,Table 3 breaksdown dual citizenship figures by age, first distinguishing between those who are adults or children at the time of the censusenumeration and then distinguishing between indi- viduals who migrated to Canada asadults compared to those who came as children. Interestingly,dual citizenshiptendencies reverse.Looking atage at the time of the census,children havehigher reported levelsof citizenshipthan their parents and other adults. Among adults, 16.1 percent declare dual citi- zenship in 1996, 10.4 percent in 1991 and 5.1 percent do so in 1981. Reported dual citizenship among children is 25.2 percent in 1996, 19.8 per- cent in 1991,and 11.8 percent in 1981. This finding is not surprising given the legalcomplexitiessurrounding children’scitizenship. In a number of cases, children may be dual citizens while their parents cannot be. In addition, if a child’sparents hold two dif- 406 INTERNATIONA MLIGRATION&VIEW ferentnationalities,upon birth the child often becomes a dejure dual citizenif the parent’scitizenshipcanbe passeddown through descent.Finally,citizenship data for children are rarelyself-reported. Parentsfillin the censusform on the child’sbehalf, and the immigrant parent might feela strong desireto identify their childrenwith both the country of origin and the new home. Parents’ reporting of their children’sdual status might not mirror the child’sperception of his or her citizenship when the latter reachesadulthood. Indeed, when we compare reported dual citizenship for immigrants who moved to Canada as adults and those who migrated aschildren, the pattern is the reverseof the previous one. Those who came to Canada as adults are more likelyto professdual nationality (17.8% in 1996; 11.2% in 1991; 6.1% in 1981) than those who moved as children (14.3% in 1996; 9.9% in 1991; 4.6% in 1981). It appears that once immigrant children enter adulthood, as many ashalf cease to identify as dual citizens. The remainder of this article focuseson adult immigrants, mostly due to the complications of citizenship law asit applies to children. At a theoret- ical level,the exclusivefocus on adults should have no adverse effecton tesr- ing the frameworksoutlined in Table 1. Allthree theories are largelybuilt on the perceptions and activitiesof adult migrants, not dependent children. DUALCITIZENSHIPAND COUNTRY OFORIGIN Aggregatefigures of dual citizenship obscure vast differences betweenimmi- grant communities. Each country has its own particular citizenship lawsthat strongly influence the ability of immigrants to legallyclaim dual nationality. The increasein reported dual citizenship shown in Table 3 reflectsindi- viduals’increased propensity to claim multiple nationalities and changes in home country laws asmore and more statesallowdual citizenship. Part of the transnational argument restson the actions of sending countries. Students of transnationalism contend that pressuresfrom nationals abroad, the need for financialand human resources,and forcesofglobalizationspur sending coun- triesto adopt dual nationality (Guarnizo, 2001). Table 4 clearlydocuments cross-nationalvariation. The table showsthe percentage ofnaturalized immigrants claiming dual citizenship for 30 signif- icant immigrant groups in 1981, 1991 and 1996.10The last column of the ’OInthis table and the following analyses, dual citizenship is defined as having at least joint citizenship in Canada and the countryrth. Excluded are dual citizenswho do not hold at least Canadian citizenship (of1all immigrants) or those whose dual nationality does not include their countofbirth(0.9% of allimmigrants). Immigrants with these multiple WHO CLAIMSDUAL CITIZENSHIP? 407 table lists whether the birth country legallyacceptsmultiple citizenship and, if this represents a legal change,the date after which dual citizenship was allowed. In many cases, these regulations become complicated. Thus, New Zealand does not have a formal law on dual citizenship but has allowed the practice by fiat since New Zealand citizenship was first established in 1949 (correspondence from government official,July 17, 2001). Argentina allows dual nationality, but does not allow nationals to hold dual passports. Dual nationals livingpermanently outside of the country must use their other pass- ports, but they can reclaim an Argentine passport if they move back to Argentina (correspondence from consular official, July 25, 2001). Poland allowsits nationals to acquire another country’scitizenship but does not rec- ognizethat citizenship,producing &fact0 dual nationals (PolishConsulate of Los Angeles website: , 2001). In some cases,governments enter into special agreements: Pakistani nationals who naturalize in Canada may be dual citizenswhile their compa- triots in the United States losePakistani citizenship. Not surprisingly,countries with higher levelsof dual citizenship tendto be those allowingmultiple nationalities. Over two fifths of naturalized Cana- dians born in Switzerland,New Zealand, Lebanon and Israel professeddual citizenshipin 1996. In comparison, lessthan 5 percent ofthose born in India, China, Germany or the Netherlands reported that they held Canadian citi- zenship and the nationality of their birthplace. Once we control for place of birth, large pluralitie- and in one case a majority - of people from states allowing dual citizenship report such a status. Claims of dual citizenship are also rising quickly.The fourth column of Table 4 calculates the percentage change in reported dual citizenship from 198 1 to 1996. In many cases,the growth is enormous: from 1981, when El Salvador did not allow dual citi- zenship, to 1996,thirteen yearsafter the law changed, claimsof dual citizen- ship increased 1,430 percent, rising from 2.3 percent in 1981 to more than 35 percent in 1996. Yet, home country citizenship regulations are neither a necessary nor sufficientcondition for dual citizenship. Home country dual nationality laws are not necessary to the extent that a minority of immigrants report dual nationality regardlessof legal statutes. This group is small- implying most immigrants are awareof dual citizenship laws - but the group’sexistencesug- nationalities had to be dropped since neither the 1981nor the 1991 censusaskedrespondents to specify their other couofcitizenship. It is consequently impossible to compare these types of citizenship over time. 408 INTERNATION MA ILRATIOR NEVIEW TABLE 4
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