What Is Citizenship by Descent and How Do I Get It?
Citizenship by descent (also called citizenship by ancestry or jus sanguinis) allows you to claim citizenship in another country based on your family lineage. If you have a parent, grandparent, or, in some cases, a more distant ancestor who was a citizen of another country, you may be eligible for a second passport without living there, passing a language test, or making a financial investment.
More than 50 countries offer citizenship by descent programs, including many of the most popular destinations for Americans: Italy, Ireland, Poland, Hungary, Germany, and Portugal. For Americans with European heritage in particular, this is often the most accessible path to dual citizenship and full EU freedom of movement.
Considering Citizenship by Descent?
Here’s how citizenship by descent works, which countries offer the best programs for Americans, what it means for your U.S. taxes, and how to get started.
How Does Citizenship by Descent Work?
Citizenship by descent is based on the principle of jus sanguinis, a Latin term meaning “right of blood.” Under this principle, citizenship is inherited through your parents or ancestors rather than determined by where you were born (which is jus soli, or “right of the soil”).
To claim citizenship by descent, you generally need to:
- Prove an unbroken ancestral link to a citizen of the country through official documents (birth certificates, marriage certificates, naturalization records)
- Show that citizenship was never broken in the chain (your ancestor didn’t renounce their citizenship before the next generation was born)
- Submit your application to the country’s consulate, embassy, or national registry with all required documentation
The specific rules vary dramatically between countries. Some, like Italy, have no generational limit and allow claims through ancestors who emigrated over a century ago. Others, like Ireland, limit claims to grandchildren of citizens. Some require basic language skills; many do not.
Obtaining a second citizenship does not affect your U.S. citizenship. The United States fully allows dual (and multiple) citizenship. You will not lose your U.S. passport by becoming a citizen of another country. Only a formal renunciation through a U.S. Embassy can end your U.S. citizenship.
Which Countries Offer the Best Citizenship by Descent Programs for Americans?
The most popular citizenship by descent programs among Americans are concentrated in Europe, where a second passport also grants EU freedom of movement across all 27 member states. Here are the programs Americans use most frequently.
Italy: No Generational Limit
Italy’s citizenship by descent program (jure sanguinis) is one of the most generous in the world. There is no generational limit, meaning you can claim Italian citizenship through a great-great-grandparent or even further back, as long as the chain of citizenship was never broken.
| Requirement | Detail |
|---|---|
| Eligible ancestor | Must have been an Italian citizen after March 17, 1861 (Italian unification) |
| Generational limit | None |
| Residency required | No |
| Language test | No |
| Key restriction | Your ancestor must not have naturalized as a citizen of another country before the next person in the lineage was born |
Italy’s program is popular but documentation-intensive. You need a complete chain of vital records (birth, marriage, death, and naturalization certificates) from your Italian ancestor through every generation to you, all apostilled and translated into Italian. Processing times vary widely, from a few months to several years, depending on the consulate.
For a detailed look at the tax implications of Italian dual citizenship, see our guide on Italian citizenship by descent and tax responsibilities.
Ireland: Grandparent Rule
Ireland offers one of the most straightforward programs. If you have at least one grandparent who was born in Ireland, you can register as an Irish citizen through the Foreign Births Register.
| Requirement | Detail |
|---|---|
| Eligible ancestor | At least one Irish-born grandparent |
| Generational limit | Grandchildren (great-grandchildren may qualify if the parent registered before the applicant’s birth) |
| Residency required | No |
| Language test | No |
| Key restriction | You must register before your own children are born if you want to pass citizenship to the next generation |
An estimated 33 million Americans claim Irish ancestry, making this one of the most widely accessible programs. Irish citizenship also grants full EU rights.
Germany: Expanded After 2024 Reform
Germany’s June 2024 nationality law reform significantly expanded access. Germany now allows dual citizenship for all naturalization cases (previously, most applicants had to renounce their existing citizenship). Citizenship by descent is available through parents, and in some cases, grandparents, who held German citizenship.
| Requirement | Detail |
|---|---|
| Eligible ancestor | Parent or grandparent who was a German citizen (special rules for descendants of Nazi-era persecution victims) |
| Generational limit | Generally parents; extended provisions for persecution descendants |
| Residency required | No (for descent claims) |
| Language test | No (for descent claims) |
| Key restriction | The ancestor must not have voluntarily renounced German citizenship |
For more on Germany’s dual citizenship rules and tax implications, see our guide on German dual citizenship.
Poland: Post-1900 Ancestry
Poland allows citizenship by descent if you have an ancestor who was a Polish citizen after 1900 and whose citizenship was never formally renounced. There is no generational limit in practice, though documentation becomes more difficult the further back you go.
| Requirement | Detail |
|---|---|
| Eligible ancestor | Polish citizen after 1900 with unbroken lineage |
| Generational limit | None (practical limit is documentation availability) |
| Residency required | No |
| Language test | No |
| Key restriction | Proof of unbroken citizenship chain required |
Hungary: Simplified Process Since 2011
Hungary’s 2011 nationality law amendment allows foreign citizens of Hungarian descent to apply for citizenship without residency requirements. Hungary has approved over one million descent-based applications since the law changed.
| Requirement | Detail |
|---|---|
| Eligible ancestor | Hungarian citizen (or citizen of former Hungarian territories) |
| Generational limit | None specified |
| Residency required | No |
| Language test | Basic Hungarian language interview |
| Key restriction | Must demonstrate Hungarian ancestry and pass a basic Hungarian language assessment |
Portugal: Grandparent Rule
Portugal offers citizenship to those who can prove they have at least one Portuguese grandparent. The program is particularly popular among Americans of Portuguese descent, especially those with ancestry from the Azores.
Other Notable Programs
- United Kingdom: Citizenship through a British parent (not grandparent, with limited exceptions)
- Greece: Citizenship through a Greek parent or grandparent; requires documentation of the ancestor’s Greek citizenship
- Spain: Available in limited cases for descendants of Sephardic Jews (program now closed to new applications) and through parents
- Lithuania, Latvia, Czech Republic: Programs available for descendants of citizens, with varying generational limits
What Are the U.S. Tax Implications of Citizenship by Descent?
This is where many Americans are caught off guard. Obtaining a second citizenship through descent is exciting, but it creates new tax considerations on both sides. Here’s what you need to know.
Your U.S. Tax Obligations Don’t Change
Acquiring a second citizenship does not reduce, eliminate, or change your U.S. filing requirements in any way. The United States taxes based on citizenship, not residency. As a U.S. citizen, you must continue to:
- File an annual Form 1040 reporting worldwide income
- File an FBAR if your foreign financial accounts exceed $10,000 at any point during the year
- File FATCA Form 8938 if your foreign financial assets exceed the applicable threshold
- Report foreign bank accounts, investments, and financial interests regardless of where they are held
This is true whether you hold one passport or five. For a deeper explanation of why, see our guide on citizenship-based taxation vs. residency-based taxation.
Your New Country May Also Tax You
This depends entirely on whether you establish tax residency in your new country of citizenship. Simply holding a passport does not usually trigger tax obligations. However, if you move to your new country and become a tax resident, you will likely owe taxes there as well.
Most countries use residency-based taxation, meaning they tax you only if you live there. Holding an Italian passport while living in the U.S., for example, does not create Italian tax obligations. But moving to Italy and establishing residency does.
Key tax scenarios for new dual citizens:
| Scenario | U.S. Tax Impact | New Country Tax Impact |
|---|---|---|
| Hold second passport but live in the U.S. | No change; file as usual | Generally no tax obligations |
| Move to new country and establish residency | Must still file U.S. taxes on worldwide income | Subject to that country’s tax laws as a resident |
| Open financial accounts in new country | Must report on FBAR and possibly FATCA | Subject to local account reporting rules |
| Earn income in new country | Report on U.S. return; use FEIE or FTC to avoid double taxation | Subject to local income tax |
Watch Out for “Accidental American” Implications in Reverse
If you obtain citizenship by descent and later have children born abroad, your children may acquire dual citizenship at birth. This is worth planning for, because children born as U.S. citizens abroad have lifelong U.S. tax filing obligations, even if they never live in the United States. This is the same dynamic that creates accidental Americans in the other direction.
Common Challenges in the Citizenship by Descent Process
Documentation Gaps
The biggest obstacle for most applicants is gathering a complete chain of vital records. You need birth certificates, marriage certificates, and often death certificates and naturalization records for every person in the chain from your ancestor to you. Records may be:
- Held by multiple government agencies across different countries
- Written in foreign languages requiring certified translation
- Missing due to war, natural disaster, or poor record-keeping
- Inconsistent (names spelled differently across documents)
Start by requesting your ancestor’s naturalization records from U.S. Citizenship and Immigration Services (USCIS) using a Freedom of Information Act (FOIA) request. These records often contain the ancestor’s original name, place of birth, and date of arrival, which can help you track down foreign records.
Processing Times
Consulates handling citizenship by descent applications are often severely backlogged. Italian consulates in the U.S., for example, may have wait times of two to five years just for an appointment. Some applicants choose to apply directly to the local municipality (comune) in Italy, which can be faster but requires a temporary stay in Italy.
The Naturalization Break
For many programs, the chain of citizenship breaks if your ancestor formally naturalized as a citizen of another country before the next person in the lineage was born. This is the single most common reason applications are denied. Check your ancestor’s naturalization date carefully against the birth date of their child.
How to Get Started
Step 1: Research Your Eligibility
Start by mapping your family tree and identifying any ancestors who may have been citizens of another country. Focus on:
- Where your grandparents and great-grandparents were born
- When they came to the United States
- Whether they naturalized as U.S. citizens (and when)
Step 2: Gather Documents
Request vital records (birth, marriage, death certificates) for every person in the chain. Sources include:
- County clerks and vital records offices in the U.S.
- USCIS for naturalization records (FOIA request)
- The consulate or embassy of the target country
- Church records, census records, and immigration manifests for supplemental evidence
Step 3: Consult an Immigration Attorney
Citizenship by descent cases can be complex, and the rules change. An immigration attorney who specializes in the country you’re claiming through can review your eligibility before you invest significant time and money in gathering documents.
Step 4: Plan for the Tax Implications
Before you open foreign bank accounts, invest in foreign property, or establish residency in your new country, talk to an expat tax professional. Understanding your FBAR, FATCA, and income reporting obligations from the start prevents costly surprises later.
Frequently Asked Questions
No. The United States fully allows dual and multiple citizenship. Voluntarily acquiring another citizenship does not affect your U.S. status. Only a formal renunciation through a U.S. Embassy can end your U.S. citizenship. Learn more about which countries allow dual citizenship.
No. Simply holding a second passport does not change your U.S. tax filing requirements. You must continue to file U.S. taxes on worldwide income regardless of how many citizenships you hold. New tax obligations only arise if you establish residency in your new country, open financial accounts there, or earn income there.
In most cases, no. The majority of citizenship by descent programs, including Italy, Ireland, Poland, and Hungary, do not require residency. You apply through the country’s consulate in the U.S. or through an agency in the country itself.
It varies widely. Irish citizenship through the Foreign Births Register typically takes 12 to 18 months. Italian applications submitted through U.S. consulates can take 2 to 5 years due to appointment backlogs. Hungarian and Polish applications generally fall somewhere in between.
In most cases, yes, but the rules vary. Irish citizenship, for example, can only be passed to your children if you registered as an Irish citizen before your child was born. Italian citizenship passes automatically through the lineage with no generational limit.
The Exclusive Citizenship Act of 2025 proposed banning dual citizenship for Americans, but as of March 2026, the bill is stalled in committee with no hearings and a 3% estimated chance of passage. Dual citizenship remains fully legal. See our full analysis of the dual citizenship bill.
This happens more often than people expect. If your parent held citizenship in a country with automatic descent rules (such as Italy), you may already be a citizen without knowing it. This doesn’t create immediate tax obligations unless you establish residency there, but it’s worth understanding your status.
Becoming a dual citizen through descent is one of the most rewarding ways to connect with your heritage and expand your options. But it also adds a layer of tax complexity that’s important to get right from the start. At Greenback, we help dual citizens and Americans abroad stay compliant across multiple countries and avoid double taxation.
If you’re ready to be matched with a Greenback accountant, click the get started button below. For general questions on expat taxes or working with Greenback, contact our Customer Champions.
Plan Your Taxes Before You Get a Second Citizenship
This article is for informational purposes only and should not be considered legal, immigration, or tax advice. Citizenship by descent eligibility requirements and processing times vary by country and are subject to change. For immigration questions, consult a qualified immigration attorney; for tax guidance, consult a qualified tax professional. For the latest on U.S. tax obligations for dual citizens, visit the IRS website.
Related Resources
- Countries That Allow Dual Citizenship: Complete List
- Italian Citizenship by Descent: Tax Responsibilities
- Does Germany Allow Dual Citizenship?
- Dual Citizenship Bill: What the Exclusive Citizenship Act Means for Expats
- Citizenship-Based Taxation vs. Residency-Based Taxation
- Accidental American Taxes: Compliance and IRS Rules
- FBAR: What It Is, Who Must File, and How to Report Foreign Accounts
- Renouncing U.S. Citizenship: Costs, Tax Implications, and Requirements
- How to Become an Expat: A Step-by-Step Guide for Americans
- U.S. Expat Taxes: The Complete Guide
