Ethnicity or birthplace: rules of citizenship vary
Israel is not the only country to struggle with the question of what defines nationality — place of birth, loyalty or ethnicity? Any child born in the United States becomes American at birth, regardless of its parents’ origins. But that’s by no means the global standard.
Here’s a look at how other countries define who belongs and who does not — an issue becoming ever more complex in a globalized world:
Germany’s system has been traditionally based on the “law of blood,” meaning a child is born German if at least one parent was German, regardless of place of birth. The system evolved from Germany’s centuries-long historical experience as a collection of small, independent states whose people developed a sense of national identity based on common language and customs that transcended borders. The system was perverted by the Nazis, who stripped German Jews of their citizenship and absorbed Austria and other German-speaking areas as part of the German homeland. This sense of ethnic identity as a basis of citizenship persisted through the Cold War, with anyone who escaped Communist East Germany being recognized as a full citizen of West Germany. After the war, ethnic Germans living in former Communist Eastern Europe could get German citizenship nearly automatically. But the system is changing and more non-Germans are qualifying for citizenship. Germany now requires all immigrants — including ethnic Germans — to pass a language and cultural awareness test before obtaining citizenship. It is also now possible for children born in Germany to longtime legal residents to obtain citizenship regardless of their ethnicity.
Iran considers children of Iranian fathers to be Iranian citizens, regardless of whether they are born in Tehran, London or Los Angeles. That provision of the law backfired on ex-Marine Amir Mirza Hekmati, who was born in Arizona to Iranian parents and was arrested in 2011 on spying charges during a visit to his Iranian relatives. The Iranians refused to allow him to meet with Swiss diplomats, who represent U.S. interests in Iran, because they considered him an Iranian citizen on the basis of his parentage. There are provisions in the law for children born inside to non-Iranian parents to be recognized as citizens, including cases of resident aliens who lived for a year in Iran after their 18th birthday. Women who marry Iranian husbands can also become Iranian.
With Ireland losing about 80,000 people a year due to emigration, the country is among the most liberal in the West in granting citizenship to foreigners who move there and take up jobs. The overwhelming majority of new Irish citizens are African and Asian immigrants who’ve been there legally for at least five of the previous nine years. Ireland also has the “grandparent rule,” which allows foreigners to take citizenship if they can prove at least one grandparent was an Irish citizen at birth. That enables many Americans, Canadians, Australians and others to travel on Irish passports even if they’ve never lived in Ireland.
Hungary lost two-thirds of its territory and half its population in treaties after World War I. The border changes then left large communities of ethnic Hungarians in neighboring countries including Slovakia, Romania and Serbia. Successive Hungarian governments have considered promoting the welfare of those communities to be a national obligation — something which has often caused friction with its neighbors over the years. The government also fast-tracks citizenship applications for ethnic Hungarians living outside the national borders. More than a half million applicants have been granted citizenship since January 2011.
The kingdom of Armenia dates from the 6th century B.C. but by the 19th century the area had been carved up by the Russian and Ottoman Empires; it later became part of the Soviet Union. As a result, Armenians fled oppression and dispersed throughout much of the Middle East and Europe, many retaining their language and national identity. Armenia won its independence in 1991 after the fall of Communism, leading to a groundswell of ethnic and national pride in a people long denied their full identity. As part of the national revival, the Armenian government reached out to the ethnic Armenian diaspora, offering expedited citizenship to Armenians living abroad.
Perhaps the world’s most unusual set of citizenship rules comes from the world’s tiniest state — the Vatican. The 110-acre (44 hectare) sovereign city state is located in the heart of Rome and is home to the pope and the Holy See, which governs the Catholic Church. The Vatican doesn’t claim to be the homeland of any single people — but in practice, everybody’s Catholic. About half of the 600 or so residents have Vatican citizenship, which is limited to the pope, resident cardinals, diplomats of the Holy See and some people who work there. Employees must take an oath that includes a profession of faith in the Roman Catholic Church, the official religion. The Church’s code of canon law and the civil law that governs life in the Vatican City State are derived from Catholic doctrine.