These Asian countries are giving dual citizens an ultimatum on nationality — and loyalty

Good overview:
Anna was born with the right to dual citizenship, because she has a Japanese mother and American father. She spent her life traveling between both countries, and says she felt deeply connected to the two cultures.
But Japan requires those with multiple passports to pick one by the age of 22 — an impossible choice for Anna, who requested a pseudonym for privacy reasons.
“I’m mixed race, I’ve lived both in Japan and the US, I speak both languages, I am completely split down the middle in terms of my identity,” she said. “It’s like asking someone whether they love their mother or father more. It’s such a cruel question.”
The past few decades have seen people travel and live abroad more, with the number of international migrants — people who changed their country of residence for at least a year — tripling from 1970 to 2015, according to the International Organization for Migration.
At the same time, tolerance to dual citizenship has generally increased. In 1960, less than one-third of countries allowed citizens to acquire a second nationality, compared to three-quarters today, according to a 2019 paper by Maartin Vink, professor of political sociology of Maastricht University in the Netherlands.
Asia is an exception to that trend. It is the world’s most restrictive region in terms of dual citizenship, with only 65% of countries and territories permitting it, according to the Maastricht Center for Citizenship, Migration and Development. To put that in perspective, 91% do in the Americas, which rank as the most liberal.
And some Asian countries are tightening their immigration laws. Japan reinforced its strict stance in January when a court upheld the country’s ban against dual citizenship, rejecting a lawsuit filed by Japanese citizens living in Europe. Hong Kong took a harder line in February, barring dual citizens from receiving consular protection — a step never before taken in the Chinese city, where dual citizenship is not legally allowed but had been tolerated.
“Dual nationality is not recognized in the Chinese Nationality Law,” said Hong Kong leader Carrie Lam in February. “That is very clear. We are strictly enforcing or implementing that particular policy.”
There are a number of reasons why the region is so resistant toward dual citizenship, including histories of conflict and colonialism. But in some countries, critics say the ban on dual citizenship also reflects a tilt toward nationalism — and the desire to maintain a monoethnic, monocultural identity.

Loyalty and nationalism

In Asia Pacific, only a few places accept dual citizenship with no caveats, including Cambodia, East Timor, Australia, New Zealand and Fiji.
Most countries are against it, although some choose not to strictly enforce their policies, allowing people to keep multiple passports by simply not declaring them. Others allow dual citizenship in restricted forms: the Philippines permits it for those who were born Filipino citizens, but not for naturalized Filipinos. South Korea allows children born to its nationals abroad to hold the passport of both their birth country and their parents.
One reason why many Asian countries oppose dual nationality is a belief that it can create divided loyalties among citizens, said Jelena Dzankic, co-director of the Global Citizenship Observatory (GLOBALCIT), an international citizenship research network. “The reason why, historically and traditionally, countries have not been permissive of dual nationality is because, whom are you going to defend if the two of our countries go to war?” she said.
Japan drafted its current nationality laws shortly after World War II, when many Japanese Americans were put in internment camps in the US; other dual citizens renounced their loyalty to the Japanese Emperor for their own safety, said Atsushi Kondo, a law professor at Japan’s Meijo University.
In one famous case, a US-born Japanese-American dual citizen worked in Japan for a company that oversaw American prisoners of war. Upon his return to the US after the war, he was sentenced to death on treason charges. He was eventually pardoned and deported to Japan — but for decades afterward, Japanese lawmakers pointed to this case as an example of the conflicting obligations that came with dual nationality.
“In wartime, double citizenship showed disadvantage,” Kondo said. “But in peacetime, dual citizens have many advantages” — including visa-free travel to more countries, greater international employment opportunities, potentially cheaper university education, and more. There are modern downsides, too — for instance, US dual citizens have to pay double taxation, but that’s not the case for most countries.
The international context has now changed, and Japan’s “beliefs are a little outdated,” he added — yet the government is reluctant to open up immigration laws and risk upsetting conservative voters.
China’s ban on dual nationality is also to ensure that its nationals are “only giving undivided loyalty to the government,” said Low Choo Chin, a history lecturer at the Universiti Sains Malaysia. During the Cold War era, China’s efforts to normalize relations with neighboring countries and end international isolation were hampered because “overseas Chinese were associated with revolutionary activities” and Communist uprisings, Low wrote in a 2016 paper. So, the Communist government formulated the current nationality law in 1980 to resolve “diplomatic frictions” and to “end divided loyalty among the overseas Chinese.”
Under Chinese President Xi Jinping, the government has cracked down on dual citizens, encouraging the public to report people secretly holding two passports. Those caught can find their access to public services curtailed.
The crackdown is part of the government’s anti-corruption efforts against “dual nationals taking advantage of the grey areas in the law, and trying to evade legal sanctions with (their) foreign nationality status … fleeing abroad, transferring their assets,” said Low, pointing to estimates by the Chinese central bank that 18,000 corrupt officials may have fled the country with 800 billion yuan ($122 billion) between the mid-1990s and 2008.
The matter of citizenship was thrust to the fore during the Covid-19 pandemic. In the midst of a crisis that transcended national boundaries, governments were suddenly faced with questions like: Which citizens do we claim as our own? For whom are we responsible? Who do we protect?
Because China doesn’t recognize dual citizenship, many Chinese nationals were forbidden from evacuating back to their country of second citizenship — even if that was their place of birth or primary residency.
There were cases of families split apart; one British woman was told she could not evacuate with her 3-year-old son because he has a Chinese passport, even though he is also a British citizen with a British passport. In the face of international pressure, the government eventually relented.

Ethnicity and blood

The idea of loyalty to a single country and culture, particularly in East Asia, may also “imply the desire to maintain a cohesive ethnocultural identity,” said Dzankic, of GLOBALCIT. Several of the countries that don’t allow dual citizenship are also highly homogenous — for instance, 92% of China is Han Chinese, according to the CIA’s World Factbook.
And one of the easiest ways for a country to control its ethnic makeup is through the type of citizenship it chooses to recognize.
There are multiple ways of obtaining a first, or second, citizenship, including through marriage, adoption and naturalization. But the most common ways are birthright citizenship (jus soli) — meaning babies automatically gain citizenship of the country they are born in — and through parental descent (jus sanguinis), which sees childrenautomatically gain the citizenship of their parents.
In Asia, the vast majority of countries today don’t recognize birthright citizenship, one of the quickest ways for ethnically foreign or minority populations to grow in a country.
Or if they do, it is so with certain conditions, according to GLOBALCIT. South Korea, for instance, only applies birthright citizenship for children whose parents are unknown or have no nationality — so if a child born on Korean soil has been abandoned, or its parents are stateless, it will receive Korean citizenship.
“A shift from jus soli to jus sanguinis has been witnessed in Asia in the course of the twentieth century,” wrote Olivier Vonk at the Maastricht Centre in a 2017 paper. Bangladesh, Indonesia, and India are among the countries that have transitioned to primarily recognizing citizenship by descent.
The type of citizenship recognized, and the rigidity of a country’s restrictions, influence how diverse or homogenous its population can be, said Kondo.
“South Korea was also a monoethnic country in the old days,” he said. “But they changed the policies, so they are more relaxed to double citizens now … And now they are considered multi-ethnic, or a multicultural country,” Kondo added.
South Korea liberalized its nationality law with sweeping amendments in 2010, which allowed permanent dual citizenship for its nationals for the first time (albeit under specific circumstances); dual citizens who fall outside those circumstances were given longer to choose; and a special naturalization path was created for talented individuals.
Japan remains strict in its nationality laws and is ethnically homogenous, said Kondo, though the government’s statistics don’t include an ethnic breakdown.
“Maybe ordinary Japanese (consider) ethnicity and citizenship as equal … Such a traditional feeling is strong in common Japanese,” he said.
Even some current politicians believe Japan “should be a monoethnic country,” he said.
Even the term jus sanguinis, citizenship by descent, implies ethnicity, said Anna, who is now based in the UK and declined to disclose her current citizenship status. The Latin translation means “right of blood,” and Japanese citizenship is built on this idea — so “the idea of blood is very strong in their understanding of citizenship.”
If a naturalized Japanese citizen who isn’t ethnically Japanese gives birth, that child would automatically become a Japanese citizen — but social attitudes and norms continue to draw lines around ethnicity, she said. There continues to be bullying in schools and a sense of social exclusion for biracial or mixed-race Japanese.
“It is this thought of blood purity … which is why even though I have Japanese citizenship, I’m not accepted as Japanese citizen in most cases because I’m not ‘purely’ Japanese as they would say … because I don’t look like them,” she said. “A lot of it is xenophobia. A lot of it is racism.”

Looking forward

The recent moves in China, Japan and Hong Kong suggest parts of Asia are moving further away from dual citizenship even as other parts of the world embrace it. Malawi, which had previously banned dual citizenship, amended its laws to allow it in 2019. Russia and Norway followed suit in 2020.
In Hong Kong, the future of dual citizenship is unclear. Though the government has insisted that it is taking a harder line in enforcement, it hasn’t provided information on what measures will be taken or how the city’s thousands of dual citizens will be affected.
“Maybe 70% of my friends have another passport,” said Janice Tam, a Hong Konger who also holds a British passport. She isn’t particularly worried about the government’s recent rhetoric — but “it depends on whether they force you to select one,” she said. “What is the consequence of that? If you’ve chosen your foreign passport, what do you still get if you stay in Hong Kong?”
Ella Wong, who holds Canadian and Hong Kong passports, is also “optimistic” that dual citizens might not be affected in their daily life. Her only concern is if Hong Kong continues to change its immigration laws to be similar to mainland China — or adopt mainland laws altogether.
“With the Hong Kong passport, you don’t know what it’s going to evolve into,” she said. “Could it become a Chinese passport, and then what does that mean in terms of travel and work and living?”
More broadly across Asia, most countries are unlikely to liberalize their laws anytime soon, said Low. The West “prioritizes liberalism, individual rights to (dual) nationality,” she said. “(But) in many Asian constitutions, access to citizenship is very tough for migrant communities because governments believe that the right to nationality is a privilege, not a right. In this context, it’s quite difficult to imagine that Asian governments would allow dual citizenship.”
Yet, experts and dual citizens remain hopeful that change will inevitably come as global migration grows. It takes time, said Vink, the Maastricht University professor.
And though they remain a minority, a few Asian countries have introduced new rules allowing for more flexible citizenship arrangements. India, for instance, created a new category of permanent residency in 2005 that allowed people of Indian descent to live and work in the country.
It’s still not dual citizenship — but it marked “a way of acknowledging the realities of a globalizing world and adapting to them step by step,” Dzankic said. “Even though countries are generally restrictive of dual citizenship, one could wonder whether those intermediate statuses could be a step or a move towards a more permissive policy.”
“I hope that the world will change,” she added. “What I think is essential or what will be important is a move towards dual nationality, not as a mechanism of being related to the state, but also as a mechanism for protecting individuals — for granting them greater life opportunities in the future.”

Source: These Asian countries are giving dual citizens an ultimatum on nationality — and loyalty

Trump’s Chain-Immigration Plan Takes Aim at Asia – Bloomberg

Noah Smith provides a detailed analysis of Asian “chain migration,” nicely contrasting the negative narrative with respect to Mexico and Central Americans with the strong economic outcomes of Asian immigrants admitted under the US equivalents to family class:

“Chain migration.” It’s a term that’s on the lips of lots of people in the immigration debate. Stephen Miller, the Trump aide who has been the most forceful proponent of immigration restriction, uses the term constantly. Originally, “chain migration” referred to the repeated use of family-reunification immigration — a man brings in his wife, who brings in her sister, who brings in her husband, who brings in his brother, and so on. Now, though, restrictionists have begun to use the term to refer to any and all family-reunification immigration.

Reducing legal family-based immigration is such a huge priority for the Trump administration that President Donald Trump offered to give unauthorized immigrants a path to citizenship — something Republicans have long opposed — in exchange for cuts to family reunification. Restrictionists’ primary target is shifting from those who enter illegally to those who enter to be with their families.

Family reunification has been one of the main ways to enter the U.S. since the reforms of 1965. Whether you want to label it “chain migration” or not, there’s no doubt that it has changed the face of the country. One of those big changes has been the creation of an important new group — Asian Americans.

In 1960, before the immigration reform, there were fewer than 1 million people of Asian descent in the U.S. — less than half a percent of the population. As of 2016, there were more than 21 million, representing almost 7 percent of the population. That’s about three times the number of Jewish Americans, and about half the number of black Americans. In states such as California and Hawaii, the Asian percentage is even larger.

Unlike Mexico, Asian countries don’t share a land border with the U.S. This means that there are two main ways for Asians to move to the country — employer-sponsored visas like the H-1B, or family reunification. In 2016, Asians were the biggest users of family preference immigration — one kind of legal immigration that Trump would mostly do away with:

Family Planning

Without family-reunification immigration, there would still be many Hispanic Americans and black Americans, but there wouldn’t be nearly so many Asian Americans. Combined, family preference and immediate family immigration (which includes spouses, minor children, and parents) accounts for a very large percent of the growth of Asian minorities:

Almost All in the Family

If adult children, parents and siblings of U.S. citizens were barred from immigrating, as under Trump’s plan, the growth of Asian America would slow dramatically. The slowdown would be even worse than these graphs show, because some highly skilled employer-sponsored immigrants would refuse to come work in the country if they couldn’t bring their elderly parents with them.

That would certainly be a slap in the face to Asian Americans, since many would take the restriction as a declaration that they are undesirable as a group. What’s more, to repudiate family-based immigration is tantamount to wishing that Asian America as we now know it had never come into existence.

Though high-skilled immigrants come from all regions of the globe, and all have been successful in the U.S., the achievements of Asian Americans are particularly well-known. Despite language barriers and lack of local ties, Asian Americans tend to be economically successful, comparing favorably to the Norwegian immigrants Trump declared he wanted:

*Excludes Taiwanese
Asian Americans also have persistently lower unemployment rates than white Americans, and their average wealth has been increasing rapidly. Beyond these blunt economic statistics, Asian Americans have contributed to the fabric of American society in countless key ways — starting companies such as YouTube, Yahoo and NVIDIA; inventing the birth control pill and AIDS treatment; directing Hollywood movies; serving in the U.S. Senate; and helping defeat the country’s enemies on the battlefield. And those are only a few famous individuals — there are many more, in addition to the countless less famous Asian Americans who have added in a million small positive ways to the fabric of the country. Meanwhile, this new group of people been integrating rapidly and deeply into American society — 46 percent of U.S.-born Asian Americans intermarry with Americans of other backgrounds.

The point here is not to glorify Asian Americans over other immigrant groups, or to imply that only famous or high-earning individuals contribute to America. The point here is merely to illustrate one clear example of a case where “chain migration” added something special to the U.S. that wouldn’t even exist otherwise.

When Miller and Trump say the words “chain migration,” you shouldn’t imagine a faceless horde of invaders coming to claim welfare benefits and live off of the largesse of the native-born. Instead, you should imagine all the good and noble human beings who have made America what it is today — the mothers and fathers, the workers and inventors, the good neighbors and friends. Before changing the country’s immigration system, we should stop and reflect on all the real benefits we wouldn’t have without it.

via Trump’s Chain-Immigration Plan Takes Aim at Asia – Bloomberg

Why China and Hong Kong must heed America’s immigration debate

Interesting commentary on the demographic challenges facing some Asian countries and the consequent need for more thought regarding their immigration policies.

Noticing that there seems to be more interest among some Asian countries in talking to countries like Canada (and likely Australia) as part of their policy makers efforts to develop or update their immigration-related policies:

…The main reason is demographic. The World Bank says East Asia is ageing faster than any other region.

China is growing older faster than almost any other country, and its low birth rate and longer lifespans means that by 2050, a quarter of the population will be over 65, with fewer and fewer young people working to support them.

Japan’s demographic crisis is well known; the population is likely to drop below 100 million before 2050, and soon after some 40 per cent of its people will be senior citizens. And Hong Kong, with its low fertility rate, has its own demographic time bomb, with its over-65 population expected to hit 24 per cent in just seven years, and a third over-65 by 2041.

They are trying to solve the problem with band-aids. China scrapped its Mao-era “one child policy” in favour of a two-child policy – and is likely to soon scrap centralised family planning altogether. Japan’s Prime Minister Shinzo Abe wants to put more women and elderly into the workforce to deal with the manpower shortage.

The real answer to the demographic challenge is immigration. New immigrants could fill the pending labour shortages, replenish the dwindling birth rates and also provide health care and home care for the growing elderly populations. But Asian countries in general, and China and Japan in particular, are not known to be hospitable to immigrants.

Accepting more immigrants would mean a cultural sea change for China, Japan and even Hong Kong, a city of immigrants. The notion of “nationhood” could no longer be predicated solely on sharing the same history, heritage and mother tongue.

In other words, Asians may have to start having the same debate currently roiling the United States – what their counties are, and what they should look like in the future.

The debate in Asia, without a history of immigration, is likely to be even more wrenching and more rancorous than the one underway in the US. But it is no less vital, if the future crisis is going to be averted.

Source: Why China and Hong Kong must heed America’s immigration debate

ICYMI: Douglas Todd: Lest we overlook the ‘Asian Holocaust’

Good piece by Todd:

Nazi Germany’s invasions and the Holocaust have been thoroughly exposed through an avalanche of books and movies. Germany’s leaders have repeatedly apologized and offered redress. And the German people, including the young, carry the guilt of their forebears’ atrocities.

That’s not the case when it comes to Japan’s war crimes.

Eugene Sledge, a U.S. professor and veteran who advised Ken Burns on his documentary, War, has said: “The best kept secret about World War II is the truth about the Japanese atrocities.”

The full horror of Japanese aggression began manifesting itself first in 1937, when Japanese soldiers launched a brutal, sexually sadistic invasion of the Chinese city of Nanking.

Peter Li, an historian at Rutgers University, continues to think Canada and the U.S. have to be held responsible for Japanese internment camps. But he also doesn’t want the world to turn a blind eye to the devastation wrought by Japan.

“As Auschwitz has become a symbol of the Jewish Holocaust and Nazi atrocities in World War II, the ‘Rape of Nanking’ has become the symbol of the Japanese military’s monstrous and savage cruelty in the Asia Pacific War from 1931 to 1945,” Li says.

“But in comparison to the Jewish Holocaust, relatively little has been written about the atrocities perpetrated by the Japanese military in China, Korea, the Philippines, Singapore and Indonesia, where close to 50 million people died at the hands of Japanese aggression. In China alone, an estimated 30 million people lost their lives.”

Given the hot spotlight on Nazi Germany, it’s little wonder those who want to shift the attention of resistant Westerners to Japan’s war crimes often use the term, “the Asian Holocaust.”

Why have Japan’s war outrages lacked the scrutiny directed at Germany?

The University of Victoria’s John Price is among those who argue one reason for the silence has been U.S. strategy since the war. After Japan surrendered in 1945, the U.S. occupied the country and turned it into an ally in its conflicts with Communist China, Korea and elsewhere. Needing a “friend” in Asia, the U.S. and other Western powers, Price suggests, have not found it in their interest to rub Japan’s nose in its iniquities.

The second reason lies in Western guilt over dropping atomic bombs on Nagasaki and Hiroshima. Those explosions helped force Japan to surrender, but at the cost of roughly 100,000 civilian lives.

As a result, in East Asia, controversy burns openly over whether Japan should more fully apologize for starting the war. But in Canada the question rarely comes up.

That’s despite Canada sending thousands of young soldiers to the Asian war, where many were killed or injured or suffered torture and mistreatment.

A person needs a strong stomach to read even a basic Wikipedia page about “Japanese war atrocities.”

Japanese military leaders often ordered troops to “Kill all captives,” says Li, editor of Japanese War Crimes: The Search for Justice. Japanese troops were routinely ordered to decapitate, rape or pour gasoline on citizens and prisoners of war.

When Japan’s soldiers weren’t burying humans alive, they were told to build their courage by plunging 15-inch bayonets into unarmed people. “Killing was a form of entertainment,” says Li. The indignities performed on corpses of victims of rape are too gruesome to cite.

Grassroots efforts to draw attention to the need for fuller Japanese apologies and redress have faced a mountain of obfuscation and denial.

Unlike in Germany, Japan’s responsibility for the war “is not clearly established in the minds of many Japanese today,” says Li. “The Japanese people have introduced the notion of ‘a good defeat’ … and they rarely invoke an enemy, or hatred for the enemy. Somehow the war has become an ‘enemy-less’ conflict.”

Last year, on the 70th anniversary of the war, Japanese Prime Minister Shinzo Abe expressed his “profound grief” for his country’s actions.

But Abe continues to send mixed messages, since he has also visited the Yasukani Shrine, which contains graves of Japan’s worst war criminals. And accounts of war atrocities remain slim to non-existent in Japanese textbooks.

Source: Douglas Todd: Lest we overlook the ‘Asian Holocaust’