Tag Archives: dual citizen from birth exemption to 877A exit tax

Canada’s new “citizenship by descent” law may benefit many U.S. citizens in unanticipated ways

Introduction and purpose of this post

In response to a 2023 Canadian court decision the Government of Canada is enacting a new law – Bill C-71. (A good analysis of the court decision is here). Assuming it is enacted, Bill C-71 may create an opportunity for certain U.S. citizens to become Canadian citizens at birth. This will this give them the usual benefits of citizenship (right to live and work in Canada). But, it may also allow them to accumulate wealth in the United States, move to Canada, renounce U.S. citizenship and avoid paying the 877A Exit Tax. Once again, we see the U.S. Tax Code has created a hierarchy of U.S. citizens. Those born with dual citizenship (U.S. and another citizenship) are “preferred U.S. citizens”. Those born with dual citizenship are the Brahmins of the USA and those born with only U.S. citizenship are the “Sudras” of the USA. In the same way that a change in a country’s criminal laws can impact extradition TO the United States, a change in a country’s citizenship laws can facilitate escape FROM the United States.

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