German dual citizenship with US and / or Canada -

Question:  I am a permanent Resident of Canada with German Citizenship.  Is there any possible way to take out Canadian Citizenship and keep my German citizenship?

david ingram replies:

You should go to and read my 12 page dissertation on dual citizenship  which you can find as the October 1993 Newsletter in the Top Left hand Box.  I have not changed a word since 1993 because it is mainly aimed at US Canada situations and when written, you could not be a dual citizen of Poland, India, Sweden or Italy.

In fact, when I started in this business in 1964, there was no such thing as dual citizenship in Canada OR the USA as part of official  government policy.  I remember a friend John H in Regina who had to make his decision at age 21 as to whether he wanted to be a Canadian (where he was born) or an American (both parents were).   Most young men in that position chose Canadian to avoid the draft.
Therefore, until a very few years ago, you could not have a lot of dual citizenships.  In reality, Canada did not allow it until Feb 14, 1977 and the US until they lost a Supreme Court case in 1980.   Since then Italy and Sweden have allowed dual citizenship and Italy is encouraging people to claim their Italian citizenship if even their grandparents were Italian.  see

I could claim British Citizenship and go and work in France tomorrow because my father was born in Liverpool on Aug 12, 1914.

Poland is encouraging the children of Polish ex pats to apply for their Polish citizenship at

India has come up with a special Indian Citizen Abroad identification - see  This is not quite dual citizenship in the Canada / US sense but does the job.  Strangely enough, one Indian citizen who became a Canadian at my urging (now working in the US with a TN), did not get his Indian Citizen Abroad card because it 'cost too much' and was a cash grab.  This was after he had spent two years complaining vociferously about the fact that he had to give up his Indian citizenship to become a Canadian.

It now appears that since 2005, there is a  method of applying for dual German / Canadian or German/American citizenship.   However, you have to apply  BEFORE you take out the Canadian or American citizenship.  You need a good reason so think hard

I found the following at:

I have no personal knowledge of the writer but do know of a couple of people who have succeeded in the request because of job situations.  - I have left English Spelling errors in place (the only German word I know for sure is 'nein'.  I do not have a clue what 'yes' is.

Henning Haarhaus
Date: 7/30/2007
Subject: obtaining dual citizenship with Germany

Hi there!  I have a friend who has a German passport, is a landed immigrant in Canada, and would like to know if she has to give up her German citizenship when obtaining her Canadian one.  She would like to be of dual citizenship. Thanks.

In principle, the German citizenship ceases to exists if a German obtains a passport of another country. As an exeption, one can file for a dual citizenship at the general counsulate which must be accomplished before the reception of the foreign citizenship. The application will be referred from there to the German authorities.

The applicant will have to provide his birth certificate and his certificate of marriage, the marriage and birth certificates of his parents, a copy of his passport, his criminal record and information about the last domicile of the parents in Germany.

There must be a good reason for a dual citizenship. As the German authorities balance careful the reasons for and against it will take the applicant some efforts to persuade them.

He must explain if and which ties to Germany he intends to keep up (living close relatives, expecting inheritance in germany, real estate in Germany, regular stays in Germany, maintaining an appartment for his own use, entitlement to a future pension from German institutions and so on).

Moreover, the applicant must explain if there is a compelling reason why he wants to take the foreign citizenship (e.g. if he wants to take up an employment which he could not get if he only had a foreign citizenship or if he wishes to take an inheritance which could not claim for by the national law if he was a foreigner). Disadvantages which are implied with a life in a foreign country in general will not be deemed sufficient.

The German authorities seek to avoid that in case of a return to Germany in the future the applicant will not apply for social benefits. For this reason, he should prove a sufficient income. Finally, the applicant should show that he speaks German sufficiently and for that reason he should present a copy of his last school report.

I hope this helps.

the writer's credentials are below

About Henning Haarhaus
I am a Certified German Lawyer and a Certified Tax Specialist Solicitor. I practice in German inheritance, inheritance tax law and civil law. I also offer my legal services in the fields of German business, tax & commercial law; e.g. business organisations, contracts; debt collections and international law.

I have been working as a German lawyer since 1999 in the forenamed fields.

Berlin Bar Association, German Association of Estate Succession and Inheritance Law, German-Korean Lawyers Association, Secretary General

Please find more information in English about German inheritance and real estate law in my online resource:

- graduated as certified banker in 1989 - passed First State Exam (JD-equivalent) in 1994 - passed exam on expertise in the field of inheritance law in 2005 - Certified Tax Expert since 2007

On April 6. 2008, David Ingram wrote:

It is very unlikely that blind or unexpected email to me will be answered.  I receive anywhere from 100 to 700  unsolicited emails a day and usually answer anywhere from 2 to 20 if they are not from existing clients.  Existing clients are advised to put their 'name and PAYING CUSTOMER' in the subject line and get answered first.  I also refuse to be a slave to email and do not look at it every day and have never ever looked at it when I am out of town. 
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However, I regularly search for the words"PAYING CUSTOMER" and always answer them first if they did not get spammed out. For the last two weeks, I have just found out that my own email notes to myself have been spammed out and as an example, as I wrote this on Dec 25, 2007 since June 16th, my 'spammed out' box has 47,941 unread messages, my deleted box has 16645 I have actually looked at and deleted and I have actually answered 1234 email questions for clients and strangers without sending a bill.  I have also put aside 847 messages that I am maybe going to try and answer because they look interesting. -e bankruptcy expert  US Canada Canadian American  Mexican Income Tax service and  help
Therefore, if an email is not answered in 24 to 48 hours, it is likely lost in space.  You can try and resend it but if important AND YOU TRULY WANT OR NEED AN ANSWER from 'me', you will have to phone to make an appointment.  Gillian Bryan generally accepts appointment requests for me between 10:30 AM and 4:00 PM Monday to Friday VANCOUVER (Seattle, Portland, Los Angeles) time at (604) 980-0321.  david ingram expert  US Canada Canadian American  Mexican Income Tax  service and help.
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Disclaimer:  This question has been answered without detailed information or consultation and is to be regarded only as general comment.   Nothing in this message is or should be construed as advice in any particular circumstances. No contract exists between the reader and the author and any and all non-contractual duties are expressly denied. All readers should obtain formal advice from a competent and appropriately qualified legal practitioner or tax specialist for expert help, assistance, preparation, or consultation  in connection with personal or business affairs such as at If you forward this message, this disclaimer must be included." e bankruptcy expert  US Canada Canadian American  Mexican Income Tax  service and help.
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Phone consultations are $450 for 15 minutes to 50 minutes (professional hour). Please note that GST is added if product remains in Canada or is to be returned to Canada or a phone consultation is in Canada. ($472.50 with GST if in Canada) expert  US Canada Canadian American  Mexican Income Tax  service and help.
This is not intended to be definitive but in general I am quoting $900 to $3,000 for a dual country tax return.
$900 would be one T4 slip one W2 slip one or two interest slips and you lived in one country only (but were filing both countries) - no self employment or rentals or capital gains - you did not move into or out of the country in this year.
$1,200 would be the same with one rental
$1,300 would be the same with one business no rental
$1,300 would be the minimum with a move in or out of the country. These are complicated because of the back and forth foreign tax credits. - The IRS says a foreign tax credit takes 1 hour and 53 minutes.
$1,600 would be the minimum with a rental or two in the country you do not live in or a rental and a business and foreign tax credits  no move in or out

$1,700 would be for two people with income from two countries

$3,000 would be all of the above and you moved in and out of the country.
This is just a guideline for US / Canadian returns
We will still prepare Canadian only (lives in Canada, no US connection period) with two or three slips and no capital gains, etc. for $200.00 up.
With a Rental for $400, two or three rentals for $550 to $700 (i.e. $150 per rental) First year Rental - plus $250.
A Business for $400 - Rental and business likely $550 to $700
And an American only (lives in the US with no Canadian income or filing period) with about the same things in the same range with a little bit more if there is a state return.
Moving in or out of the country or part year earnings in the US will ALWAYS be $900 and up.
TDF 90-22.1 forms are $50 for the first and $25.00 each after that when part of a tax return.
8891 forms are generally $50.00 to $100.00 each.
18 RRSPs would be $900.00 - (maybe amalgamate a couple)
Capital gains *sales)  are likely $50.00 for the first and $20.00 each after that.

Catch - up returns for the US where we use the Canadian return as a guide for seven years at a time will be from $150 to $600.00 per year depending upon numbers of bank accounts, RRSP's, existence of rental houses, self employment, etc. Note that these returns tend to be informational rather than taxable.  In fact, if there are children involved, we usually get refunds of $1,000 per child per year for 3 years.  We have done several catch-ups where the client has received as much as $6,000 back for an $1,800 bill and one recently with 6 children is resulting in over $12,000 refund. 

This is a guideline not etched in stone.  If you do your own TDF-90 forms, it is to your advantage. However, if we put them in the first year, the computer carries them forward beautifully.
This from "ask an income trusts tax service and immigration expert" from or or David Ingram deals on a daily basis with expatriate tax returns with multi jurisdictional cross and trans border expatriate problems  for the United States, Canada, Mexico, Great Britain, United Kingdom, Kuwait, Dubai, Saudi Arabia, Thailand, Indonesia, Japan, China, New Zealand, France, Germany, Spain, Italy, Russia, Georgia, Brazil, Peru, Ecuador, Bolivia, Scotland, Ireland, Hawaii, Florida, Montana, Morocco, Israel, Iraq, Iran, India, Pakistan, Afghanistan, Mali, Bangkok, Greenland, Iceland, Cuba, Bahamas, Bermuda, Barbados, St Vincent, Grenada,, Virgin Islands, US, UK, GB, and any of the 43 states with state tax returns, etc. Rockwall, Dallas, San Antonio Houston, Denmark, Finland, Sweden Norway Bulgaria Croatia Income Tax and Immigration Tips, Income Tax  Immigration Wizard Antarctica Rwanda Guru  Consultant Specialist Section 216(4) 216(1) NR6 NR-6 NR 6 Non-Resident Real Estate tax specialist expert preparer expatriate anti money laundering money seasoning FINTRAC E677 E667 105 106 TDF-90 Reporting $10,000 cross border transactions Grand Cayman Aruba Zimbabwe South Africa Namibia help USA US Income Tax Convention. Advice on bankruptcy  e bankruptcy expert  US Canada Canadian American  Mexican Income Tax service and help .

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