Cutting the Ties? Generational Limitations in Canada’s and Germany’s Citizenship Laws

Abstract

This paper compares Canada’s and Germany’s citizenship laws with regard to regulations that delimit the acquisition of citizenship abroad. It finds that the respective regulations are designed similarly, but differ in some details. The Canadian regulation, for instance, prevents citizenship from being passed on to the second generation born abroad, whereas the German rule offers an opportunity to retain citizenship without seriously giving proof of a link to the country. From a normative point of view, there are good reasons to delimit the acquisition of citizenship abroad, but also for an opportunity to retain citizenship if people have a genuine link to the state and its political system. The regulations of each country show deficits in this respect. Thus, this paper suggests introducing requirements for an entitlement to regain citizenship for second or subsequent generations born abroad which could be designed similarly to the requirements for immigrants who want to naturalize.