What sparked my interest this morning was a reference in this collection of articles to Turkey and Germany. Germany is a state known for its jus sanguinas citizenship laws which meant that citizenship was transmitted by "blood" and not by place of birth (just soli). This meant that the children of immigrants and their children were not German at birth and that led to a large population of resident aliens many of whom were of Turkish descent. This is not the only country where this has happened: Japan still has a large population of Koreans who are "special permanent residents" but not citizens.
I note that some of the resident Koreans are descendants of individuals who did have citizenship at one point and lost it after World War II. Today they can apply for naturalization and many have. In Germany Jewish citizens were stripped of their German nationality before World War II and Article 116 of the German Constitution allows them and their descendants to reacquire German citizenship. Peter Spiro, an American citizenship scholar whose books I highly recommend, did so in 2013.
German citizenship law changed in the year 2000 when a limited form of jus soli was introduced and Turks (and others) were allowed to naturalize under certain conditions. However, for the most part the German rules against dual citizenship remained for non-EU migrants. Renunciation of all other citizenships is required in most cases (as it is in Japan).
The renunciation requirement is not always enforceable. It's hardest to enforce when it's a birthright citizen who goes out into the world and naturalizes in another state since states don't generally inform other states about who naturalizes. It's not impossible to enforce, however. One method might be to ask during a consulate administrative procedure like passport renewal for the citizen abroad to produce her residency papers or visa for the state of residence. From my experience (and let me know if yours is different) consulates abroad don't do this which effectively makes dual citizenship "tolerated."
Enforcing a dual citizenship ban is easiest when it concerns a naturalized citizen. The receiving state can require proof of renunciation of the prior citizenship before granting citizenship (or making it contingent on the presentation of the necessary documents). Both Germany and Japan do ask for this as part of the naturalization process.
But that, it turns out, is not foolproof either and Turkey is an excellent example of the kind of counter move another state can make against another state's citizenship laws. One is the easy reacquisition of a former citizenship citizenship and the other is a special status conferred on those living outside the national territory who have ostensibly renounced which nonethless allows them to retain most of the rights of citizenship including the right to return and so on.
According to this 2012 EUDO report, in 1981 Turkey changed its citizenship laws and permitted dual citizenship as long as the person who acquired another informed the Turkish government of the fact. It also allowed Turks to be "released" from Turkish citizenship and then permitted them to have it reinstated once the naturalization process in the other country had been completed. Neat trick.
The Germans then turned around and changed their law to allow them to unmake a German citizen who had "illegally" taken on another citizenship after becoming German. And they did. At least the ones they were able to find. (And how they found them deserves its own post.)
In 1995 The Turkish government created a special status for its former citizens abroad.
"[T]the amendment created a privileged noncitizen status. This status permits holders of a pink card to reside, to acquire property, to be eligible for inheritance, to operate businesses and to work in Turkey like any citizen of Turkey. Pink card holders were only denied the right to vote in local and national elections." (p. 6)Another neat trick. One could argue that this is just citizenship under another name. Note that one had to be a birthright citizen of Turkey in order to have this status and it was "never intended to include the minorities who left Turkey before 1981." This was primarily about Turks in Germany, not an open door for the acquisition of rights by other former residents and citizens. Fascinating.
In 2004 Turkey extended some of the rights of these non-resident-sort-of-citizens and they renamed the Pink Card the Blue Card.
In 2017 the Turkish Blue Card is still around. Have a look at this government website which says who is eligible and what rights and exemptions this status confers.
Question: Is this an acceptable compromise? Naturalized citizens can retain the right to return and reside in the home country but they can't vote and they are exempted from things like military service. Would this be a partial solution to the issue of citizenship-based taxation? For those of you who are naturalized, would you accept a status like this in your former country of citizenship? Would you have liked to have had that option?