Meghan Markle: Citizenship and Religious Conversion

[Osipi]

Originally Posted by Purrs

As a dual citizen with an American parent, I was not born in the USA, never made in any money there and have never lived there, I'd renounce my American citizenship in a minute if I could. I have no desire to ever move there as I live in country with a much better health care system. My loyalty is to the country where I was born and have lived all my life. Not all of us want to be American.

Unfortunately the American IRS (Internal Revenue Service) has put people like me in a double jeopardy position.

I'm supposed to file American taxes as well in my own country - supposed to pay double taxes - taxes to both countries!!! I don't file American taxes because my income is below a certain threshold. (I get tax refunds from my home country). At this point in time, the IRS doesn't bother with lower income dual citizens. I have been advised that however, currently if I had an annual income of $1 million or over, I would have to file with the IRS or be in legal trouble. (Our financial institutions must report holdings to the IRS for dual American citizens due to a treaty my country signed with the USA.) When my American parent dies, the IRS will tax their estate along with this country also taxing it. (They also hold dual citizenship and have spent 3/4 of their life outside the US in this country.)

American taxes will be a concern for both Meghan and Prince(ss) Sussex. Unlike other countries, the US taxes nonresident citizens, my home country and most countries do not. I really doubt the British Royal Family wants to have to pay American taxes.

If I attempt to renounce my American citizenship, I have to agree to a 5 year audit by the IRS, a very expensive process that I cannot afford as well as paying a very large fee for renunciation which I also cannot afford.

Frankly, the American citizenship is a millstone that I wish my parent had never gotten for me. (The USA changed its tax policies to taxing nonresidents years after I became a dual citizen.)

Dual citizenship + dual taxes (in the case of a Baby Sussex with a substantial inheritance/wealth) = dual pain in the back of the front if you ask me.

Personally, I am of the opinion that Meghan should renounce her US citizenship upon becoming a citizen of the UK and never, ever urge their child(ren) to claim US citizenship. Neither of them really need that US citizenship really but the US is always looking for another citizen to tax.

[Tatiana Maria]

Originally Posted by Purrs

American taxes will be a concern for both Meghan and Prince(ss) Sussex. Unlike other countries, the USA taxes nonresident citizens, my home country and most countries do not. I really doubt the British Royal Family wants to have to pay American taxes.

Originally Posted by Osipi

Dual citizenship + dual taxes (in the case of a Baby Sussex with a substantial inheritance/wealth) = dual pain in the back of the front if you ask me.

Personally, I am of the opinion that Meghan should renounce her US citizenship upon becoming a citizen of the UK and never, ever urge their child(ren) to claim US citizenship. Neither of them really need that US citizenship really but the US is always looking for another citizen to tax.

According to the legal site below (and I have read the same advice given in cases of possible US citizenship on other websites), the tax obligations of American citizenship apply also to American citizens who have never documented their citizenship.

Overseas American Citizens: When You Need to File a Tax Return or Pay U.S. Taxes | Nolo.com

It bears noting that U.S. tax laws apply to all American citizens, including those who may have never taken affirmative steps to document their citizenship by way of procuring a U.S. passport. Indeed, people who may not know that they are U.S. citizens—a scenario occurring with some frequency in the context of children born abroad to U.S. citizens who acquire citizenship by derivation – and who have never been to the United States are subject to United States tax law.

This indicates that as far as the legal issue goes, it is necessary for the children to take active steps to renounce their American citizenship in order to liberate themselves from any American tax liabilities.

But realistically, I imagine it is highly unlikely that the American government would seek to enforce penalties on high-profile members of the British royal family, particularly children who have never set foot in America, even if they were noncompliant with their American tax obligations.

Originally Posted by HighGoalHighDreams

Tatiana, we are in agreement... that was the point of my flippant comment. There was also no room for disagreement on the Wessex issue, but people persisted in "interpreting" the plain language of the law until someone wrote to an official about the specific case of Louise and James. Only then did people accept what was plainly written-- and in fact, some people still do not accept it!

I was making the point (jokingly) that, regardless of how much people point to what is written in the law, or from official sources, until someone writes to an official and says about this case "Excuse me, but is Baby an American citizen?" after she is born, people will persist in believing what they will!

Thank you for the clarification, and I apologize for my misunderstanding. I personally feel the confusion over the Wessex titles to be understandable due to the fact that, if I'm not mistaken, the sovereign's prerogative to regulate titles by announcement is established through Britain's unwritten law (rather than a written statute which can be easily searched for), which is why I did not understand the analogy correctly.

[jacqui24]

Originally Posted by Purrs

As a dual citizen with an American parent, I was not born in the USA, never made in any money there and have never lived there, I'd renounce my American citizenship in a minute if I could. I have no desire to ever move there as I live in country with a much better health care system. My loyalty is to the country where I was born and have lived all my life. Not all of us want to be American.

Unfortunately the American IRS (Internal Revenue Service) has put people like me in a double jeopardy position.

I'm supposed to file American taxes as well in my own country - supposed to pay double taxes - taxes to both countries!!! I don't file American taxes because my income is below a certain threshold. (I get tax refunds from my home country). At this point in time, the IRS doesn't bother with lower income dual citizens. I have been advised that however, currently if I had an annual income of $1 million or over, I would have to file with the IRS or be in legal trouble. (Our financial institutions must report holdings to the IRS for dual American citizens due to a treaty my country signed with the USA.) When my American parent dies, the IRS will tax their estate along with this country also taxing it. (They also hold dual citizenship and have spent 3/4 of their life outside the US in this country.)

American taxes will be a concern for both Meghan and Prince(ss) Sussex. Unlike other countries, the USA taxes nonresident citizens, my home country and most countries do not. I really doubt the British Royal Family wants to have to pay American taxes.

If I attempt to renounce my American citizenship, I have to agree to a 5 year audit by the IRS, a very expensive process that I cannot afford as well as paying a very large fee for renunciation which I also cannot afford.

Frankly, the American citizenship is a millstone that I wish my parent had never gotten for me. (The USA changed its tax policies to taxing nonresidents years after I became a dual citizen.)

I don’t believe I ever said it’s a dream of everyone to live here. But some do prefer as I do. I’m well aware of the tax consequences as I’m a CPA. But US estate tax allows an exemption of $10 million or so per estate, so unless your parents are worth $20 million or more, it’s not as bad as you are making it out to be.

As for Meghan, the only thing that would’ve been an issue is her rent free arrangement at KP that would be subject to tax liability without credit from taxes paid to UK govt. can someone tell use what Uk investment income rate is at this point? Don’t think it’s that much below US if at all.

Originally Posted by Osipi

Dual citizenship + dual taxes (in the case of a Baby Sussex with a substantial inheritance/wealth) = dual pain in the back of the front if you ask me.

Personally, I am of the opinion that Meghan should renounce her US citizenship upon becoming a citizen of the UK and never, ever urge their child(ren) to claim US citizenship. Neither of them really need that US citizenship really but the US is always looking for another citizen to tax.

The biggest tax is really on estate rather than inheritance tax. And as dual citizens living abroad, they won’t be subject to state jurisdiction for inheritance tax anyways. Estate tax is often equated with inheritance tax, but it’s not. Estate tax is death tax, and assessed on the person who died’s estate. Not the person inheriting it. So unless Meghan is expected to have a $10+ million estate, it’s not applicable. As for anything she may inherit from a non-US resident, no estate tax would assessed regardless. As for income, a dual citizen, or ex-pat for that matter, gets credit for foreign taxes paid. It’s only if US taxes are higher that they’ll incur liability.

[muriel]

Originally Posted by jacqui24

It was discussed back when the announcement was made and before that the Home Secretary would have the discretion to move things along quicker. Exceptions certainly have been made in other countries as well.

And what other conclusion should I draw based on what is happening? Fact of matter is, at this point, this child will be born with dual citizenship. And it was about as clear as you can get that, when they announced the engagement, they weren't going to wait 5 years to try for children. This scenario isn't exactly a shocker to anyone.

The BRF and the government took the view that they would not speed up or side step the immigration process and system in place for Meghan. That does not, in any way, suggest that they were accepting the notion of dual-citizenship for Meghan for life.

[BaiSoSo]

There was a time that I was indifferent about a dual citizenship or British citizenship but after the way the media cried about OWNing her because she doesn't want to do a photo call right after the birth of the baby (WTH) and the recent news about some in the BRF, I changed my mind and was like no Meghan you need to keep your American citizenship these people don't have your best interest at heart. At the end of the day that is what it comes down to what is in the overall best interest of Meghan (and her/Harry's children).

Having dual citizenship isn't going to change the way Meghan approaches her job within the BRF, she is still going to do her homework. She is still going to look for ways/projects to help those in the UK, Commonwealth and even world wide, that is just part of who she is as a person. She doesn't have to give up her roots to be successful.

[muriel]

Originally Posted by BaiSoSo

Having dual citizenship isn't going to change the way Meghan approaches her job within the BRF, she is still going to do her homework. She is still going to look for ways/projects to help those in the UK, Commonwealth and even world wide, that is just part of who she is as a person. She doesn't have to give up her roots to be successful.

This may well be hypothetical as we don't quite know what Meghan actually intends to do. However, IMO, it is a terrible message to take to the government and people of the UK that Meghan will represent them (as it comes with the role of consort to a member of the royal family) but frankly is unwilling to commit to sole UK citizenship. If there were to be a conflict of any sort (not necessarily a military one) between the UK and the US, what side would she be on? The BRF are part and parcel of the soft diplomacy that we engage in. What side would her interests lie? As you can see the issues are complex, and that is why you can't sit on the fence on this one. Mary of Denmark, Maxima of the Netherlands have all given up their previous citizenships to join the royal families they married into.

[wyevale]

^ If the Duchess declines to become a British subject.. that would give further fuel to the view that she isn't committed to this country/marriage or new life..

That isn't solely the view of the gutter press.. I hear it whispered by monarchists who would NEVER read such bile filled rags.. the idea is taking root, and once that happens will be hard to eradicate.
Hopefully all the cooing over the baby will stop it in its tracks...

[Mbruno]

Originally Posted by muriel

This may well be hypothetical as we don't quite know what Meghan actually intends to do. However, IMO, it is a terrible message to take to the government and people of the UK that Meghan will represent them (as it comes with the role of consort to a member of the royal family) but frankly is unwilling to commit to sole UK citizenship. If there were to be a conflict of any sort (not necessarily a military one) between the UK and the US, what side would she be on? The BRF are part and parcel of the soft diplomacy that we engage in. What side would her interests lie? As you can see the issues are complex, and that is why you can't sit on the fence on this one. Mary of Denmark, Maxima of the Netherlands have all given up their previous citizenships to join the royal families they married into.

Máxima has not given up her Argentinian citizenship. Apparently she claims it is impossible to renounce Argentinian citizenship under Argentinian law or, at least, that is what the Dutch members posted on TRF.

Both Mary and Máxima were fast tracked though for naturalization respectively in Denmark and in the Netherlands.

[muriel]

Originally Posted by Mbruno

Máxima has not given up her Argentinian citizenship. Apparently she claims it is impossible to renounce Argentinian citizenship under Argentinian law or, at least, that is what the Dutch members posted on TRF.

Both Mary and Máxima were fast tracked though for naturalization respectively in Denmark and in the Netherlands.

YOu are right about the Argentinian citizenship for Maxima. It seems clear that she does not have a choice, unlike Meghan, where there is a clear process for giving up US citizenship.

[muriel]

Originally Posted by wyevale

^ If the Duchess declines to become a British subject.. that would give further fuel to the view that isn't committed to this country/marriage or new life..
That isn't solely the view of the gutter press.. I hear it whispered by monarchists who would NEVER read such bile filled rags.. the idea is taking root, and once that happens will be hard to eradicate.
Hopefully all the cooing over the baby will stop it in its tracks...

I agree. This will be an unnecessary self goal (and not the first one, IMO!) on the part of Meghan.

[loonytick]

Do we know if the Duchess of Gloucester still maintains her Danish citizenship? What about the citizenship of a Princess Michael or Autumn Philips? I know their situations and positions are not the same, but I’m curious what the context is.

[JR76]

Originally Posted by loonytick

Do we know if the Duchess of Gloucester still maintains her Danish citizenship? What about the citizenship of a Princess Michael or Autumn Philips? I know their situations and positions are not the same, but I’m curious what the context is.

It's only been possible for Danish citizens to hold dual citizenships since 2015 so I'd assume that the Duchess is a British citizen.

[Tatiana Maria]

Originally Posted by muriel

This may well be hypothetical as we don't quite know what Meghan actually intends to do. However, IMO, it is a terrible message to take to the government and people of the UK that Meghan will represent them (as it comes with the role of consort to a member of the royal family) but frankly is unwilling to commit to sole UK citizenship. If there were to be a conflict of any sort (not necessarily a military one) between the UK and the US, what side would she be on? The BRF are part and parcel of the soft diplomacy that we engage in. What side would her interests lie? As you can see the issues are complex, and that is why you can't sit on the fence on this one.

I completely understand the point you are making, and as you pointed out, it is what is expected in similar monarchies. However (to my great surprise), the British government and the British people have demonstrated that they are comfortable even with a person who has never been a British citizen, has never set foot in Britain, and speaks no English becoming the British monarch(!). When the Succession to the Crown Act remade the laws of succession a few years ago, no steps were taken to remove the thousands of foreigners with no connections to Britain from the British line of succession.

Originally Posted by wyevale

^ If the Duchess declines to become a British subject.. that would give further fuel to the view that isn't committed to this country/marriage or new life..

It was announced at the time of the engagement that Meghan Markle would seek to apply for British citizenship and remain an American citizen during the process (which is expected to last at least five years under the present residence rules). What has not been announced is whether she will renounce her American citizenship once she is naturalized.

[jacqui24]

Originally Posted by wyevale

^ If the Duchess declines to become a British subject.. that would give further fuel to the view that she isn't committed to this country/marriage or new life..

That isn't solely the view of the gutter press.. I hear it whispered by monarchists who would NEVER read such bile filled rags.. the idea is taking root, and once that happens will be hard to eradicate.
Hopefully all the cooing over the baby will stop it in its tracks...

Two things:

1) She will become a British subject. I’m not sure where the indication is that she isn’t. It has been announced that she’s in the process. That’s not what we are discussing here. The issue is if she should renounce her American citizenship years down the line. Especially given her child(ren) will also carry dual nationality until at least 18. It also brings up the question of necessity at that point. After all, she’ would have carried out engagements for on behalf of the monarch for 5 years (at least, possibly longer as she has to count out the days where she’s not in UK) as foreign national. At least by that point, she’d be a citizen of UK as well. And some of us think she shouldn’t given the way she’s been treated.

2) It was a decision made with all the high up consulted that there will not be fast tracking on her UK citizenship, so why are the monarchists whispering it’s her that’s not committed? She’s going through the process and seems to be as committed as anyone that’s married someone from Britain and moved there with the intention of making it their permenant home. Or is this another one of those things where we’ll blame her for something that’s beyond her control?

[muriel]

Originally Posted by loonytick

Do we know if the Duchess of Gloucester still maintains her Danish citizenship? What about the citizenship of a Princess Michael or Autumn Philips? I know their situations and positions are not the same, but I’m curious what the context is.

Originally Posted by JR76

It's only been possible for Danish citizens to hold dual citizenships since 2015 so I'd assume that the Duchess is a British citizen.

The Duchess of Gloucester is British. I don't know about Princess Michael or Autumn Phillips, but as they do not carry out engagements on behalf of the BRF, their citizenship is not relevant.

[Fijiro]

Meghan is not the only foreigner to marry into the British Royal Family. There are others, eg. Duchess of Gloucester, Princess Michael of Kent, and Autumn Phillips.

And, as loonytick posted earlier, it would be nice to know if the Duchess of Gloucester maintained her Danish citizenship, and if Princess Michael maintained hers, or if Autumn Philips keep her Canadian citizenship.

.

[jacqui24]

Originally Posted by muriel

The BRF and the government took the view that they would not speed up or side step the immigration process and system in place for Meghan. That does not, in any way, suggest that they were accepting the notion of dual-citizenship for Meghan for life.

But they are accepting a foreign national for 5 years and her children, who are actually in line to the throne, for at least 18 years. I would say dual citizenship for life isn’t that far of a stretch. Or is this another we don’t have to make an effort, but you must do everything above and beyond?

[Fijiro]

Originally Posted by muriel

The Duchess of Gloucester is British. I don't know about Princess Michael or Autumn Phillips, but as they do not carry out engagements on behalf of the BRF, their citizenship is not relevant.

Duchess of Gloucester is Danish.


Princess Michael of Kent - Czech
Autumn Philipps - Canadian

[muriel]

Originally Posted by Fijiro

Duchess of Gloucester is Danish.

To clarify, British by naturalisation.

[Fijiro]

Originally Posted by muriel

To clarify, British by naturalisation.

Question is, did she give up her Danish citizenship after naturalization?