Meghan Markle: Citizenship and Religious Conversion

[Osipi]

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]

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.

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.

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]

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.

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]

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]

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]

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]

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]

^ 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]

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]

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.

^ 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]

^ 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]

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.

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]

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]

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]

Duchess of Gloucester is Danish.

To clarify, British by naturalisation.

 

[Fijiro]

To clarify, British by naturalisation.

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

 

[O-H Anglophile]

Duchess of Gloucester is Danish.


Princess Michael of Kent - Czech
Autumn Philipps - Canadian

We know the DoG is from Denmark-the question was does she still have Danish citizenship

 

[Fijiro]

We know the DoG is from Denmark-the question was does she still have Danish citizenship

I have not seen anything to indicate that the Duchess of Gloucester gave up her Danish citizenship. So I would assume she is a dual citizen.

Also, I have not seen anything to indicate that Princess Michael of Kent gave up her Czech citizenship, or that Autumn Philipps gave up her Canadian citizenship. So I would assume that they too are dual-citizens.

.

 

[muriel]

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.

IMO, the children potentially being dual citizens for 18 years is a complete red herring as they will not be conducting royal engagements or representing the government when they are children.

As regards a transitional 5 years, as mandated by due process and regulation, becoming permanent, I think that is indeed a far stretch.

Or is this another we don’t have to make an effort, but you must do everything above and beyond?

More like, we welcome you to our land, give you a wedding "the stuff fairy tales are made of", we put you at the pinnacle of society, access to resources and a lifestyle you are not accustomed to or could previously only imagine, provide you with round the clock security. In return, you agree to support your husband who, as a grandson of the monarch and the second son of the next monarch, will carry out engagements in support of crown and country. In return, you commit to serve the UK, and the UK above all else. No surprises there!

 

[jacqui24]

More like, we welcome you to our land, give you a wedding "the stuff fairy tales are made of", we put you at the pinnacle of society, access to resources and a lifestyle you are not accustomed to or could previously only imagine, provide you with round the clock security. In return, you agree to support your husband who, as a grandson of the monarch and the second son of the next monarch, will carry out engagements in support of crown and country. In return, you commit to serve the UK, and the UK above all else. No surprises there!

She does serve the UK. And she has done so since before her marriage. Last I checked, she’s not carrying out work on behalf of the American government.

And since you are on the topic of the law and how that makes it ok for her to represent the monarch as a foreign national. The law also indicates the government is ok with someone having dual citizenship. So I still don’t see them having any issue with it.

 

[Fijiro]

IMO, the children potentially being dual citizens for 18 years is a complete red herring as they will not be conducting royal engagements or representing the government when they are children.

As regards a transitional 5 years, as mandated by due process and regulation, becoming permanent, I think that is indeed a far stretch.



More like, we welcome you to our land, give you a wedding "the stuff fairy tales are made of", we put you at the pinnacle of society, access to resources and a lifestyle you are not accustomed to or could previously only imagine, provide you with round the clock security. In return, you agree to support your husband who, as a grandson of the monarch and the second son of the next monarch, will carry out engagements in support of crown and country. In return, you commit to serve the UK, and the UK above all else. No surprises there!

Same as Duchess of Gloucester, who as far as I know still holds her Danish citizenship. I have not seen any record of her rescinding her Danish Citizenship.

 

[muriel]

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.

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

We know the DoG is from Denmark-the question was does she still have Danish citizenship

I have not seen anything to indicate that the Duchess of Gloucester gave up her Danish citizenship. So I would assume she is a dual citizen.

As JR76 pointed out, Danish citizens have only been allowed since 2015 to hold dual citizenship, so it can safely be assumed that the Duchess of Gloucester only holds British citizenship.

Also, I have not seen anything to indicate that Princess Michael of Kent gave up her Czech citizenship, or that Autumn Philipps gave up her Canadian citizenship. So I would assume that they too are dual-citizens.

.

The nationalities of Autumn Phillips and Princess Michael of Kent are not relevant as they are not working members of the BRF and do not represent the crown or the UK in any way.

 

[Ista]

She does serve the UK. And she has done so since before her marriage. Last I checked, she’s not carrying out work on behalf of the American government.

And since you are on the topic of the law and how that makes it ok for her to represent the monarch as a foreign national. The law also indicates the government is ok with someone having dual citizenship. So I still don’t see them having any issue with it. Hell, wasn’t your Foreign Secretary dual citizen until he got fed up with an IRS bill?

I have no idea if Meghan will retain her US citizenship, but if she chooses to do so, it would send a distinct message about her commitment to the country she has chosen to represent. It might not be the message she intends, but a message nevertheless.

 

[Kataryn]

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.

Yes,but they were offered their new nationality before they married. I think this is a very different thing from Meghan, who had to stay US-American even though she represents the queen already in the highest places. So IMHO it is up to her to repell or keep her US-citizenship just as she wishes to.

More like, we welcome you to our land, give you a wedding "the stuff fairy tales are made of", we put you at the pinnacle of society, access to resources and a lifestyle you are not accustomed to or could previously only imagine, provide you with round the clock security. In return, you agree to support your husband who, as a grandson of the monarch and the second son of the next monarch, will carry out engagements in support of crown and country. In return, you commit to serve the UK, and the UK above all else. No surprises there!

There is no way she agreed "to serve the Uk and the Uk above all else". She is still an US-American and her baby will be one as well. Her baby will be a member of the BRF, but that's something else entirely. When it is time to accept the British citizenship, she mighjt or might not get rid of her Us-American passport, but till then she is US-American and has a right to stay that till the end of her life.


Btw - couldn't Harry have applied for an US-American citizenship, now that he is married to an US-American?

 

[muriel]

Yes,but they were offered their new nationality before they married. I think this is a very different thing from Meghan, who had to stay US-American even though she represents the queen already in the highest places. So IMHO it is up to her to repell or keep her US-citizenship just as she wishes to.

Not quite. The law and regulations of the land will take their course. Once she is a British subject, there will be an expectation that she will renounce her US citizenship. If she chooses not to, the message, intended or otherwise, will be clear to all.

 

[jacqui24]

I have no idea if Meghan will retain her US citizenship, but if she chooses to do so, it would send a distinct message about her commitment to the country she has chosen to represent. It might not be the message she intends, but a message nevertheless.

Bottom line is the British government has created a scenario where a foreign national is representing their head of state, and they seem ok with government officials carrying dual citizenship as well. I would think the latter would've been a bigger risk than a member of royal family who carries out duties that either are told by the government or for charitable causes only. If the split loyalty is such an issue and so important for the British, they can simply not allow dual citizenship. It's rather easy. As it stands, this doesn't seem to be a concern for them.

Not quite. The law and regulations of the land will take their course. Once she is a British subject, there will be an expectation that she will renounce her US citizenship. If she chooses not to, the message, intended or otherwise, will be clear to all.

Here's my issue with that. The law and regulations of the land is taking course if she does not renounce. The law of the land is allowing dual citizenship. Even at high levels of government, apparently. And that is a choice of the government. So, in terms of expectation, who is it from? It's obviously not from HM or the government.