Citizenship Studies

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The grey area between nationality and citizenship:

an analysis of external citizenship policies in Latin
America and the Caribbean

Luicy Pedroza & Pau Palop-García

To cite this article: Luicy Pedroza & Pau Palop-García (2017) The grey area between nationality
and citizenship: an analysis of external citizenship policies in Latin America and the Caribbean,
Citizenship Studies, 21:5, 587-605, DOI: 10.1080/13621025.2017.1316701

To link to this article: https://doi.org/10.1080/13621025.2017.1316701

Published online: 19 Apr 2017.

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Citizenship Studies, 2017
VOL. 21, NO. 5, 587–605
https://doi.org/10.1080/13621025.2017.1316701

The grey area between nationality and citizenship: an analysis

of external citizenship policies in Latin America and the
Caribbean
Luicy Pedroza and Pau Palop-García
Institute of Latin American Studies, German Institute of Global Area Studies, Berlin, Germany

ABSTRACT ARTICLE HISTORY

Literature on diaspora engagement policies, transnational and extra- Received 8 February 2016
territorial citizenship has painted the increasing recognition of dual Accepted 9 March 2017
nationality and the extension of state policies to the diaspora as a KEYWORDS
signal of states leaving behind the paradigms of exclusive nationality Citizenship; discrimination;
and residence as conditions to exercise citizenship. In doing this, this mobility; rights; status;
literature tends to treat citizenship and nationality as synonyms. By nationality
analysing the citizenship policies of 22 Latin American and Caribbean
states towards their nationals who reside abroad and/or acquire
another nationality, we add key nuances to such consideration:
nationality and citizenship may relate to different legal statuses –
with important consequences for migrants – and there might be
differences also between the citizen rights of nationals by origin and of
nationals by naturalization. In particular, we show that citizenship and
nationality interact in different ways when it comes to the preservation
of rights for emigrants: the distinctions allow restricting the portability
of citizenship rights for nationals by birth, and other groups of
nationals, depending on the exclusivity, and origin, of their national
belonging. These distinctions tell a potentially different story of how
citizenship is conceived of by states as they approach the challenges
of membership and participation posed by emigration, and paint a
less rosy picture with regard to the demise of exclusive nationality.

Studies of comparative citizenship policies have often under-analysed the distinction

between citizenship and nationality, as if these were terms with minor, and practically
meaningless semantic differences. While this might be true in some legal traditions, there
are many countries where this distinction carries substantial consequences, and where
it is used to make further distinctions between nationals, depending on the source and
moment of their acquisition of nationality (at birth or later). This distinction is particularly
common in Latin America and the Caribbean. It is thus imperative that the comparative
literature recognizes these distinctions where they exist, since they make a difference in
the extent to which different groups may become or remain members of a polity. Below the
superficial tolerance to dual nationality, states keep setting limits on how fully emigrants

CONTACT  Luicy Pedroza  luicy.pedroza@giga.hamburg

© 2017 Informa UK Limited, trading as Taylor & Francis Group
588   L. PEDROZA AND P. PALOP-GARCÍA

continue to belong, and these limits determine whether they keep a full citizen voice or
not if they live and have become naturalized elsewhere. This conceptual point is potentially
important for any kind of citizenship claim made beyond the territorial borders of the
state, but it is especially important in light of the claims made in relation to extraterritorial
citizenship, diaspora engagement policies and transnationalism. These literatures tend
to look at the preservation of citizenship-as-nationality without further distinctions and
derive conclusions about possibilities for overlapping memberships while, as we will show,
there might be none or might be only enjoyed by some kinds of nationals. The reason is
that policies regarding the preservation of nationality and citizenship after emigration are
primordial in defining the very population to which external citizenship and diaspora
engagement policies apply to.
With a comparative study of citizenship and nationality laws as they affect emigrants
from 22 Latin American and Caribbean (henceforth LAC) states, we show that there are
observably distinct state policy patterns regarding the preservation of nationality and cit-
izenship, and that, where it exists, this distinction has momentous consequences to define
who is eligible for maintaining nationality and citizenship despite being non-resident or
acquiring other nationalities. We can show with this survey of original data for a whole
region – which has often been assumed to fall in the same historical and cultural tradition
– that distinct models exist within, proving that it is crucial to control for this distinction.
In the following pages, we first briefly survey the bodies of literature to which our con-
ceptual and empirical contribution applies. Second, we review the distinction between
citizenship and nationality from three angles: a theoretical, which shows its relevance from
a conceptual and normative point of view; a historical, which throws light on its roots in
Latin America; and an empirical one, which looks at its relevance for emigrants. Third,
we introduce our data and methods. Fourth, we describe and analyse the policies of LAC
states regarding the nationality and citizenship of nationals who leave and adopt a further
nationality with a wide comparative perspective, and providing case illustrations. Finally,
we draw conclusions from our findings for the comparative citizenship studies literature.

The unequal citizenship of emigrants

For over two decades, the literature on ‘transnationalism’ has shown the simultaneity with
which migrants lead their lives in political, social and economic levels in several political
communities. After classic studies of transnationalism prompted analysts to focus on
other actors than the state, students of political transnationalism focused on the effect of
transnational activity on the integration of migrants in host societies or the political activity
of migrants to their countries of origin (Portes, Guarnizo, and Landolt 1999; Østergaard-
Nielsen 2003). A yet newer literature seeks to understand the policies by which states reach
out to their populations abroad. Through in-depth case studies (Delano 2009; Naujoks
2012) or cross-sectional designs (Lafleur 2005; Martiniello and Lafleur 2008; Gamlen 2014;
Collyer 2013; Ragazzi 2014), scholars have found different models of ‘emigrant policies’,
implying different conceptions of statehood and citizenship beyond the nation state territory
(Itzigsohn 2000; Bauböck 2010). For these policies, emigrants are targeted qua citizens of
their states of origin – whatever that means. Citizenship policy is then, without doubt, the
area of policy that is most decisive to determine whether emigrants are meant to be included
in the state policies towards those it considers its members beyond borders. Until now,
 CITIZENSHIP STUDIES   589

studies of citizenship policy in general, and in Latin America in particular, have mostly
studied differentiations made regarding immigrants (Wollny 1991; Joppke 2005; Barbulescu
2011; Scott Fitzgerald and Cook Martin 2015), and to some extent, emigrants (Bauböck
2009; Collyer 2014). Yet, the differentiations made regarding the very possibility to retain
citizenship among emigrants who are nationals by origin, as opposed to those who only
naturalized, have not been unveiled. Such differentiation makes palpable the extent to which
states have truly overcome fixations with loyalty in their toleration of dual nationality and
the exercise of citizenship from abroad (i.e. through external voting) or not: for those who
are nationals by birthright, the portability of citizenship seems to be more and more granted,
but for dual nationals and nationals by naturalization – at least in LAC – further migration
comes at the cost of loss of citizen rights, or even nationality.
In most Latin American states, it is well established by historians that a long-standing
legal tradition has differentiated between nationality and citizenship (Jones-Correa 2001;
Escobar 2007; Vonk 2014), yet these and other relevant studies on external citizenship still
treat citizenship and nationality largely as synonyms. In this paper, we show what it means
that such distinction is ignored in LAC, and potentially further, with a comprehensive
comparative study.

Citizenship and nationality in LAC and beyond

Over time, the conventional use of the terms citizenship and nationality in Latin America
has come to approximate the treatment given to citizenship as a synonym of nationality in
the rest of the world. Yet, there is one fundamental difference between the use of these terms
in most of the academic literature in English and in Latin America. While in the former the
distinction is mostly a theoretical one, in LAC the distinction is explicit and meaningful
in a legal sense. Most generally, nationality refers to the condition and privileges derived
from having a passport (i.e. the right to return, the right to claim diplomatic protection
from the state in third countries, the right to transmit nationality through ius sanguinis),
while citizenship refers to the set of rights and duties/between the state and the individual,
especially the political-electoral.1
Yet, as warned by Jones-Correa (2001, 998), ‘dual nationality does not necessarily entail
access to all the rights and benefits of national citizenship, such as voting or the right to hold
office’. In this paper, we show how and for how many countries this is true in the region of
LAC. Moreover, we observe something that has been overlooked in the literature: depending
on whether one is a birthright national (i.e. acquired nationality at birth through ius soli o
ius sanguinis) or not, the very capability or eligibility to exercise rights that are exclusive of
citizens (the right to vote and be elected, or to hold different kinds of office) might be at stake.
The ensuing sections explore this differentiation from theoretical, historical and empirical
angles. Each helps us refine our research questions and clarify what these differentiations
entail.

The distinction of citizenship and nationality in theory

The notion of citizenship has a wider field of application than nationality. This is recognized
by most scholars – with exceptions in international law, where citizenship is used widely,
even though nationality is meant (e.g. Ginsburg and Dixon 2011). Citizenship is a classical
590   L. PEDROZA AND P. PALOP-GARCÍA

concept related to political life in general, in both its formal and informal aspects; that is,
to the attribution of rights that allow persons to participate in public life and to their very
exercise of those rights, and can notably also be related to polities below the state level.
Nationality, in contrast, is related to the rise of nation states as the main kind of polity to
which membership must be defined. Yet, some scholars explicitly choose to treat them as
synonymous for the purpose of comparative empirical analyses (Faist 2001a, 7, 8; Dugard
2006, 208; Vonk 2014, 25).2
The emergence of nationality as pole of identification and membership flattened the
different meanings that citizenship had, with some exceptions.3 Still today, however, an
implicit distinction remains: while nationality refers to nation state membership, citizenship
still refers widely to rights of political voice, participation and representation potentially
derived from it, but substantiated by other criteria as well, in a way such that only when
both are present is full citizenship in effect. This implicit distinction becomes palpable
when conditions are spelled to exercise full citizenship, for instance: reaching majority of
age to gain franchise. Migration also brings this distinction to the fore. Emigrants are gen-
erally recognized to remain nationals of their countries of origin and thus preserve a cross-
national political standing through that status, with important rights to mobility, access
to job market, residence and diplomatic protection derived from it. However, such recog-
nition of nationality not always entails full citizen inclusion in the political community of
origin. Some legal regulations reinforce models of emigrant citizenship as a passive bundle
of rights barely more substantive than nationality, with little requirements of effective use
or, often, no right of use.
Recently, Bauböck made a contribution to this theoretical debate avoiding the concept
of nationality altogether. He proposes that the relevant distinction is between citizenry and
demos; the first being composed by all individuals recognized as members by the governing
institutions of a democratic polity, or who mutually recognize each other as belonging to
such a polity; and the second as those within the citizenry who enjoy full political rights
(2015, 2). This contribution permits conceiving of other concepts (old and contemporary)
which denote a political community, and the rightful criteria for inclusion in it. Some such
concepts could be found in the history of early Latin American nations: nativeness and
neighbourhood.

The distinction between citizenship and nationality historically

Most of the countries covered here (16) maintain a distinction between nationality and
citizenship, with minor wording deviations.4 This is the result of a lineage of laws dating
back to the texts that inspired the constitutional assemblies of the newly independent LAC
states. The distinction prevails until today, at times disguise and at times in utter contradic-
tory displays, in the heavily reformed relevant texts of their constitutions and nationality
laws and regulations.
According to François-Xavier Guerra (1999), effective citizenship in Latin America has
been historically the most restricted of a series of up to five concentric circles. To him, each
circumscribed different groups with different rights: in the bigger one, the whole population
(historically, also slaves); then, those with civil rights (free men, foreign and national); then,
the nationals; then, the citizens who were the nationals who held political rights to elect and
be elected (excluded women, minors, foreigners and castes); and finally, the citizens who
 CITIZENSHIP STUDIES   591

could use those rights (i.e. who were not suspended from their use by any reason such as
unemployment or criminal offenses). Guerra shows that these distinctions mixed traditional
and modern liberal criteria, harbouring a potential schism for different political categori-
zations of the new Latin American nation states. This would become a durable source of
tension for categorisations in migration and citizenship policy (see, for example, Cantor,
Freier, and Gauci 2015).5 The mixed categorizations of citizenship and nationality were
inspired by the French and American Revolutions as much as by the Cádiz Constitution
(see Carmagnani and Chávez 1999), a late colonial product which, in an unprecedented
concessions to Americans, defined nationals (Spaniards) as: ‘all free men born in or resident
in the territories of the Spains [!] and their children; foreigners with a letter of naturaleza, or
those without it who have been neighbours [vecinos] for over ten years […]’(Constitución
de Cádiz, 1812, arts. 18, 19). According to Herzog (2007, 157), the Cádiz Constitution
already differentiated between Spaniards and Spanish citizens. Citizenship, required for
office holding, could be suspended for misdemeanour, and it was lost if citizens acquired
another nativeness (naturaleza), or lived for over five years outside Spain.
Benedict Anderson associated early Latin America with the rise of nationalism, yet a
thick conception of the nation seems to have been less decisive than the mutual local social
recognition expressed in those norms in order to exercise citizenship. The new independ-
ent nations would take different directions to define their political communities, yet the
common origin of their trajectories is evident in early policy preferences.6 For instance,
they all sought to attract immigration into deserted areas, to create national citizens quickly
and prevent the preservation of foreignness in resident groups over generations. Thus, cit-
izenship laws were geared to attract immigrants and to make the acquisition of nationality
automatic for new generations born in the territory, with a preponderant ius soli principle
for birthright acquisition. The presence of foreigners who were long residents but refused
to take nationality was deeply resented. Moreover, residence acquired a very special quality
as a condition – sometimes sufficient – for citizenship.
The fundamental characteristics to attest residence, however, were far from objective and
did not depend, for example, on the census. At the core of the recognition of citizenship
was the social recognition of having a stake in the public affairs of the local community
as neighbour (see Annino et al. 1995; Irurozqui 1996; Sábato 1999). A neighbourhood
represented an almost natural or familial relation that linked together all inhabitants of a
town by virtue of their common interests and qualified them to enjoy local benefits and
to intervene in the municipal administration as a elector or elected (del Castillo Velasco
1875). This had roots in Spanish colonial practices of social recognition of ‘being native’
(i.e. nationality) for immigrants who settled down. Foreigners who settled and acquired
property, married or resided long enough, could be considered ‘natives’ by their neighbours,
even without any official process of naturalization (Herzog 2007, 154). The parallel to this
was that emigrants could lose nativeness.
After centuries of being excluded from the vote due to the full citizenship and exclusive
franchise being reserved for Spaniards born in Iberian Spain, independentist elites had
only recently struggled to demand civic and political rights for people born in American
territory, including those ‘racially’ mixed. Against this backdrop, it is remarkable that local
social validation sufficed for acquiring citizenship in the new Latin American nations.
More importantly, lacking proof of nativeness could be outweighed by socially recognized
integration. They set a contrast to the previous custom in Spanish America to recognize
592   L. PEDROZA AND P. PALOP-GARCÍA

vecindad (i.e. local citizenship based on neighbourhood) to naturales only (i.e. reputably,
persons perceived to be native of the larger political community).
Eventually, however, the development of communities into massive polities made this
social recognition impossible as a criterion to determine citizenship. Instead, an objective
standardized requisite of residence, attestable through documents, took pre-eminence, and,
in most places, formal membership to the (larger) nation became a prerequisite to belong
to the citizenry, so that the persons who composed the citizenry, in Bauböck’s terms (2015),
had to be either nationals by origin, or naturalized.
In spite of this, in Latin America the formal distinction between citizenship and nation-
ality persisted. The historical relevance of residence in Latin America helps to understand
why some of its countries would take a distinctive approach to the attribution of citizenship,
from their early steps as nations onwards (Quiroga Lavié 1991, 57), as Section ‘Data and
findings’ will show, even keeping a variant of the distinction that was closer to the historic
notion of neighbourhood as criterion to be recognized a citizen. The interesting questions
are: Where did this distinction prevail, in which guise and with which consequences?
We will answer this question from the prism of emigration, as we think – and will show
next – that emigration is a relevant phenomenon that shows the contemporary relevance
of these different notions of citizenship.

The distinction between citizenship and nationality for emigrants

Bearing in mind the overwhelming disapproval of dual nationality in international law
just half a century ago, it is remarkable that most states nowadays allow people to combine
internal and external memberships (Vink 2013, 14). This development has been a result of
the reduction in warfare between countries and demise of military conscription, as well as
expansion of an international human rights regime (Faist and Kivisto 2007). More generally
still, it follows the realities of migration, as a result of international couples and their offspring,
and of the mix of principles of attribution of citizenship by birth (jus soli and jus sanguinis)
(Faist 2001b; Aleinikoff and Klusmeyer 2001). Yet, we want to stress the inequalities in the
retention of full citizenship for nationals who are absent and/or acquire another membership,
despite the general tolerance of dual nationality, since it brings to the fore not only the
implications of the differentiation between citizenship and nationality for the portability of
citizen rights, but also the inequalities among nationals in their citizen rights.
Literature on dual citizenship is abundant. From pioneering studies (Hammar 1985), to
the philosophical problems that pertain from conceiving it as membership in nations across
borders (Schuck 2002; Bauböck 2010; Spiro 2010) that enables democratic participation
from different normative perspectives (Blatter 2011), to its consequences for allegiance
towards the different polities of membership (Schlenker 2015). In comparative empirical
studies, Latin America stands out as the region that recognizes dual citizenship the most
(Vink and De Groot 2010). By now, research has shown that maintaining ties with the
origin country does not preclude successful integration in the residence country (Guarnizo,
Portes, and Haller 2003), and indeed that the preservation of the nationality of origin leads
to a better integration of emigrants in their countries of residence (Mazzolari 2009; Vink
2013). Yet, we claim that before researching the reasons to adopt or support these policies
or studying their consequences it is crucial to look carefully at the kinds of ties extended
by extraterritorial citizenship and its distinctions.
 CITIZENSHIP STUDIES   593

Dual nationality most often entails the opportunity to participate politically in the
countries of nationality, but as Martiniello and Lafleur (2008) warn, there are also cases
where ‘dual citizenship does not entail dual membership in the respective political com-
munities, and indeed restrict them to a time limit of absence, or to certain conditions
that serve as proxies to reassure the political communities that a genuine link is kept alive
despite the distance’. We will now show that membership may be equated to nationality,
yet not to citizenship: even as LAC states formally allow their emigrants to remain ‘long-
term, long-distance partners’ (Levitt 2001), group differentiations among the nationals
remain thanks to the persistence of the historical distinction between citizenship and
nationality.
The potential relevance of this distinction has been hinted at by some authors. Ernst
Hirsch Ballin has called attempts to distinguish these terms ‘pointless, unless law does it’
(2014, 21). Escobar, who realizes the distinction is indeed legally relevant in Latin America
(2015, 928) does not explore it – and seems to have come to this realization slowly, having
noted some years ago that emigrants’ political incorporation in their countries of origin ‘has
been slower than the abandonment of the exclusivity of citizenship and is not yet a reality
in many others, where it continues to be a point of contention’ (2007, 68). Bauböck too
(2007, 2426), is aware that the chances of either exercising external citizenship or having
dual nationality give emigrants a ‘slightly different standing’– similar to Jones-Correa (2001).
Fox (2005) even proposes that dual nationality is the only transnational citizenship because
it denotes enforceable rights in clearly bounded membership(s) enabling a high intensity
in their use. But are emigrants truly enabled to exercise citizen rights to the same degree in
two polities? Some of these accounts seem to suggest that memberships (and citizenships,
whenever the distinction is ignored) add up, with dual nationality opening more options
than mono-external citizenship. Our evidence of the differentiation between citizenship
and nationality suggests something different.
What we propose is that they may interact in different ways. In theory, this means that
if we disaggregate external citizenship into portability of rights and exclusivity of citizen-
ship, we get potentially different stories of how citizenship is conceived of by states as they
approach the challenges of membership and participation posed by emigration. This paper
invites to think about about these – meaningful – different stories. We ask specifically: Do
states of origin force emigrants to choose a membership? Do they deactivate citizenship after
residence abroad? Do they differentiate between groups of emigrants in this deactivation?

Method of analysis
The data that we present in this analysis are taken from the EMIX Data-set, which covers
information about a broad range of emigrant policies designed by 22 LAC. The analysis
draws specifically upon indicators on the acceptance of dual/multiple nationality, loss of
nationality and loss of citizen rights (by adoption of a second nationality or by residence
abroad). The data were collected consulting primary sources, national legislative texts and
complemented by case law and secondary literature. Some variables included are coded
dichotomously, indicating, for instance, the recognition or not of dual nationality (1-0).
The others are measured with a ratio scale ranging from 0 to 1, where 0 always corresponds
with the more restrictive scenario theoretically possible, and 1 with the more permissive.
594   L. PEDROZA AND P. PALOP-GARCÍA

Before we start presenting the data, three brief conceptual clarifications are due. First, we
look at the toleration of emigrant dual citizenship, that is, that which applies to those who
reside abroad and take up another nationality, and the qualities of and conditions to preserve
it; not in dual nationality tout court, or in general principles of transmission of nationality,
but only those that are relevant to emigrants. Second, we use dual and multiple nationality
interchangeably, as we focus on the legal capacity to hold another nationality. Third, when
we refer to citizen rights, we mean the compound of what is conceived as citizenship in
each case, and not the specific electoral rights that many countries have extended to their
emigrants – which display great variation in types of rights (active/passive), levels of elec-
tions reached (local, regional, national), representation mechanisms for emigrant votes, etc.7

Data and findings

Non-exclusivity of belonging
The indicator ‘non-exclusivity of belonging’ (EXCLUSIVITY) informs about the toleration
of the overlap of national allegiances (i.e. abandoning notions of nationality as being unique
and exclusive). It ranges from 0, when the given country does not allow the adoption of
another nationality; and 1, for the ideal cases where (1) dual/multiple nationality is tolerated,
(2) there are no restrictions of citizen rights due to the acquisition of another nationality,
(3) the regulation is applicable without limit to subsequent migrant generations and (4)
dual nationality is tolerable for all countries without differentiation. If a country tolerates
dual nationality, but it imposes restrictions or conditions for the exercise of citizen rights
abroad, the score is nuanced.
Figure 1 presents the scores of the indicator of non-exclusivity of belonging for the
22 LAC states included in the sample. At the aggregated level, the LAC countries tend
to tolerate other nationalities for their nationals by birth (EXCLUSIVITY: mean = 0.73,
SD = 0.28) and more restrictive for naturalized nationals (EXCLUSIVITY: mean = 0.51,

Figure 1.  Non-exclusivity of belonging for nationals by naturalization and by birth. Source: Own
Elaboration based on EMIX.
 CITIZENSHIP STUDIES   595

SD = 0.4). However, at the individual level, we find countries that apply the same rules to
all nationals, disregarding the mode of acquisition of the nationality status (e.g. Bolivia,
Brazil or Costa Rica).
Dominican Republic, El Salvador, Honduras, Nicaragua, Trinidad & Tobago and
Venezuela have the highest score of the non-exclusivity of belonging for nationals by birth
indicator. However, only Venezuela applies the same regulation for nationals by birth and
by naturalization. The rest of countries are more restrictive; especially Trinidad & Tobago
does not allow its naturalized citizens acquiring further nationalities.8
There are countries that tolerate dual nationality for nationals by birth, but impose a limit
regarding the generation. This is the case of Ecuador, Mexico, Chile, Belize, Uruguay, Bolivia,
Costa Rica and Guatemala. In Ecuador, for example, dual nationality is only tolerable until
the third grade of consanguinity (La Constitución de La Republica de Ecuador 2008, Art.
7.2) and in Costa Rica for first generation emigrants (Asamblea Nacional Constituyente
1949 Art. 16.).
Argentina, Colombia, Jamaica, Panama, Paraguay and Peru tolerate the acquisition of
another nationality, but restrict substantially the compendium of citizen rights recognized
to the nationals who acquired another nationality. Cuba is the only country in our sample
that does not –formally – tolerate dual nationality for either nationals by birth or nationals
by naturalization.

Portability of citizen rights

The indicator portability (PORTABILITY) accounts for the possibility of losing the nation-
ality status if an individual establishes its residency abroad. It ranges from 0, if there is an
automatic loss of nationality when a person resides abroad less than 5 years; and 1 in the
case that residency abroad is not a cause of loss of nationality. The scores are nuanced if the
country imposes restrictions of citizen rights due to the establishment of formal residency
abroad.
As in exclusivity, some countries apply more restrictive rules to naturalized nationals
(for nationals by birth, PORTABILITY: mean = 0.97, SD = 0.11; for nationals by natural-
ization, PORTABILITY: mean = 0.64, SD = 0.47). For instance, residing abroad is cause
of loss of nationality for naturalized nationals in Belize, Dominican Republic, El Salvador,
Jamaica, Mexico, Paraguay and Uruguay (see Figure 2(a)) and cause for loss of citizen
rights in Honduras. However, no country deprives its nationals by birth of nationality for
establishing permanent residency abroad (Figure 2(b)). In Uruguay, though, establishing
residency abroad leads to a suspension of citizen rights until the individual moves back to
Uruguay (Poder Legislativo 1967 Art. 81). Argentina and Uruguay seem to have developed
a citizenship tradition of their own that, in the view of Quiroga Lavié (1991, 57), ignores
the distinction between citizenship and nationality. Yet, on a closer look it is clear that they
do differentiate between them, and fundamentally so. To clarify this, we devote a short
section to these cases below.

Different patterns of non-exclusivity of belonging and portability of citizen rights

The qualitative gradations in both non-exclusivity of belonging and portability of citizen
rights, and the combinations thereof, are presented schematically in Table 1, which allows
596   L. PEDROZA AND P. PALOP-GARCÍA

Figure 2. Portability of citizen rights for citizens by naturalization and by birth. Source: Own Elaboration
based on EMIX.

Table 1. Portability and non-exclusivity of belonging for nationals by birth.

  Portability of citizen rights Exclusivity of belonging
Cuba Yes Exclusive
Argentina Yes Non-exclusive, but restrictions of citizen rights
Colombia Yes and regarding the toleration of subsequent
Paraguay Yes generations
Jamaica Yes Non-exclusive, but restrictions of citizen rights
Nicaragua Yes
Panama Yes
Belize Yes Non-exclusive, but restrictions regarding the
Bolivia Yes toleration of subsequent generations
Brazil Yes E.g. In Ecuador dual nationality is only tolerable
Chile Yes until the third grade of consanguinity and
Costa Rica Yes in Costa Rica only for the first generation of
Ecuador Yes emigrants
Guatemala Yes  
Mexico Yes  
Dom. Republic Yes Non-exclusive
El Salvador Yes  
Honduras Yes  
Peru Yes  
Trinidad & Tobago Yes  
Uruguay Restriction of citizen rights if residence abroad  
conditional to return
Venezuela Yes  
Source: Own Elaboration based on EMIX.

us to highlight two current tendencies in the regimes of citizenship and nationality for
emigrants in LAC. First, that they are overwhelmingly geared to allow emigrants to keep
their citizen rights beyond the borders of the state of origin. No country in LAC (not even
Cuba, with obscurely defined ‘expatriation’ clauses), deprives its nationals by origin of their
citizenship merely for emigrating; the only relevant gradation in portability is a suspen-
sion of citizen rights (i.e. but not nationality loss), while abroad. Second, that the relevant
 CITIZENSHIP STUDIES   597

variations across citizenship regimes relate to non-exclusivity: citizen rights can be restricted
upon taking up another nationality, or/and upon the transmission of the nationality of the
origin state to further generations born abroad. This suggests that countries of origin take
the combination of emigration with the acquisition of a further nationality as an indicator of
a longer term commitment to another political community, and sufficient ground to restrict
citizenship, if not withdraw it. Only seven countries avoid restrictions even in these cases,
delineating the most inclusive regime of citizenship for emigrants found to be in practice
(Table 1). Incidentally, they are all countries of net high emigration.

Closer to its roots: citizenship in Uruguay, Argentina and Paraguay

States around the Río de la Plata seem to have kept citizenship understandings close to
their Latin American roots – see supra Section ‘The distinction between citizenship and
nationality historically’, the concepts of nativeness and vecindad. In the early legal history of
Uruguay, the concepts citizenship and nationality were sometimes used interchangeably, but
eventually nationality disappeared from the legal texts. In Uruguay, the term ‘national’ was
discarded in favour of ‘natural’, which would make sense to understand the term ‘natural-
ized’, but this confuses some scholars because precisely the term ‘naturalization’ is avoided
in Uruguayan law. ‘Legal citizenship’ is used instead for the citizenship that immigrants
acquire after only two years of through legal residence. This all means that Uruguay confers
citizenship primarily upon residence, but still distinguishes orientales (i.e. those born in the
country) as those with a privilege to activate or deactivate their citizen rights depending
on residence, from the rest. Children born to Uruguayans abroad are nationals, but not
citizens; likewise, foreigners acquire citizenship through residence, but lose it upon emi-
grating. Today, only orientales are citizens jure soli, and only while they remain residents.
Thus, while both orientales and naturales are Uruguayan nationals by birth, they differ in
their capacity to hold citizenship, and to transmit nationality to further generations (León
2007, 440): outside Uruguayan territory nationality can be inherited, but not citizenship.9
For born-abroad Uruguayans to become citizens, they need to become residents in Uruguay
(León 2007, 439).
In Argentina, the sense of the differentiations between nationality and citizenship is
similar, but not equal. This becomes palpable in specifications regarding dual nationality.
Emigrants who accept a second nationality by naturalization have their political rights in
Argentina suspended,10 unless there is a treaty of dual nationality with the other coun-
try involved, as is the case with Colombia, Chile, Ecuador, El Salvador, Spain, Honduras,
Italy, Nicaragua, Norway, Panama, Sweden and the United States. In these cases, Argentina
understands double nationality as a situation where one nationality is fully effective, while
the other is dormant, depending on residence (Oyarzábal 2003, 44). Someone with double
nationality and permanent residence in one of the above-mentioned countries, for instance,
will be treated as a foreigner on Argentine territory. Upon taking up residence in Argentina,
the Argentine nationality becomes the dominant one and citizenship is activated.11
The legal framework in Paraguay, another neighbouring country, suggests there
might be a distinct branch of citizenship evolution in this Latin American sub-region.12
Paraguay already shares characteristics with the rest of the continent, but as in Uruguay and
Argentina,13 residence is a strong condition for the activation of a passive ‘natural’ allegiance.
Following practice in the rest of the continent, Paraguay does not strip nationality of its
598   L. PEDROZA AND P. PALOP-GARCÍA

nationals by origin by any means, but does suspend their citizenship, like Argentina, if they
acquire another nationality, unless otherwise regulated by bilateral treaties (Constitución
1992, Art. 153).

Not all emigrants were born equal: citizenship in Central America

A closer look at the Central American and Caribbean cases in the middle cells of Table 1
highlights a further sense in which the distinction between citizenship and nationality has
tangible consequences for citizens who emigrate, depending on whether they are nationals
by birth, or not. To illustrate this, it suffices to look at the differences in the extraterritorial
citizenship rights kept by nationals by origin and those kept by nationals per naturalization.
Figure 3 shows the result of the aggregation of the two previous measures (EXCLUSIVITY
and PORTABILITY)14: some countries that are reputably quite generous towards their
nationals abroad still discriminate those who are nationals by naturalization. Mexico shows
the highest difference here.
While nationality for Mexicans by birth cannot be lost under any circumstance, Mexicans
by naturalization lose nationality (and thereby also citizenship), for either taking another
nationality, or for residing five years abroad (Constitución 1917, Art. 37: A, B). Belize
follows its northern neighbour closely; only citizens by registration (naturalization) can
lose their nationality after five years of absence, or only two if they go back to the country
where they originate from (Nationality Act 2000, 21, 1). A deeper distrust in the loyalty of
naturalized persons is palpable even if they became long term residents, both in Mexico and
Belize, where naturalized citizens are banned from a broad range of public service positions
(not only electoral posts) (Law Revision Commissioner 2000, art. 26; Hoyo 2015, 19). This

Figure 3. Differences between regulations applied to nationals by naturalization and by birth. Source:
Own Elaboration based on EMIX.
 CITIZENSHIP STUDIES   599

discrimination exists too, if weaker, in Jamaica and Dominican Republic, where residence
abroad for over 7 and 10 years, respectively, is enough to lose nationality.
Again, Paraguay and Uruguay deserve a separate mention because although their nat-
uralized nationals may lose their nationality (thus also citizenship) if they reside abroad
over seven years, or acquire another nationality, the part of this restriction that refers to
citizenship extends to nationals by origin too. Their citizenship regimes are closer to resi-
dence as a main criterion and generally more restrictive of citizen rights upon emigration.

Discussion of findings
This paper has shown that, where it exists, the distinction between citizenship and nation-
ality is instrumental to compartmentalize different citizen rights across groups who are
ranked in their membership, and may lead to the paradoxical situation that even though
dual nationality recognizes full membership of persons in two polities (as widely recognized
in the literature), it limits the citizenship of emigrants. In their pioneer comparative study
on electoral rights of non-resident nationals, Nohlen and Grotz note that terms such as
‘citizenship’, which are used so differently in different contexts, remain unspecified unless we
reach for expertise on the contexts of their institutionalization (2007, 66). This is certainly
true for Latin America as a region, and our comprehensive analysis shows that even within
regions institutionalization trajectories may be different, with important consequences for
the kinds of groups that are created within the larger set of nationals, each able to exercise
extraterritorial citizenship to a different degree. We want to close this research paper by
drawing conclusions that are valid for all countries, and then separating those that are
specific to LAC countries.
Around the world and without any need to differentiate between citizenship and nation-
ality explicitly, countries practically do differentiate in the degree to which they recognize
participation rights to their diaspora, according to different understandings of their contri-
bution and stake. The fundamental distinction between a general belonging and a specific
right to have a say in a community (citizenry and demos, for Bauböck) crystallizes through
migration. Revising the effective content of external citizenship reveals these distinctions.
What difference does it make that such distinction is explicit in a majority of LAC coun-
tries, then?
The formal distinction serves to regulate extraterritorial citizenship. It makes a substantial
difference in both the status of membership, and the condition of citizenship, depending on
how exclusively emigrants belong to the country of origin, and on whether they belong since
birth or not. Regulating nationality allows states to restrict the rights of mobility, protec-
tion and return that come with the status of nationality, while restricting citizenship may
allow them to dampen the influence that persons suspected of an impure loyalty or lost
connection may have in domestic politics. Lastly, it tells a theoretically meaningful story
about citizenship, in at least three senses.
In a first sense, it tells us that, despite a strong general tendency to tolerate the acqui-
sition of further nationalities across LAC countries, the acceptance of multiple national
memberships does not mean homogeneous and unrestricted acceptance of simultaneous
citizen rights. This means that general claims about the abandonment of exclusivity through
the acceptance of dual nationality might need to be toned down in the literature: multiple
belonging may subtract citizenship from nationality. As Bauböck (2010) points out, migrants
600   L. PEDROZA AND P. PALOP-GARCÍA

and their family members can be seen as agents who choose between alternative citizenship
options. From this perspective, a citizenship opportunity structure needs to be taken into
account to understand migrants’ choices, which is under the control of both the state of
origin and the state of residence. However, citizenship policies of both origin and receiving
countries produce legal statuses and bundles of rights that are not equal for all. To under-
stand that, we need to properly observe any group differentiation made. Having done that
here, we showed that the rights deriving from the recognition of multiple nationality are
not always additive or intermittent (i.e. relying on residence as in Uruguay, Argentina and
Paraguay). In several LAC countries, dual nationals are restricted in the rights they enjoy
when they are absent vis-à-vis mono-nationals.
In a second sense, but in line with the first, our findings suggest that countries of emi-
gration are very active in applying to their emigrants the stratification of citizen rights that
Cohen (2009) found to be a constant of citizenship history within a nation, resulting in many
in-between categories. In our view, the discrimination we found in many countries towards
nationals by naturalization who emigrate merits special attention, even if it numerically
affects very few, because it demonstrates that the extension of extraterritorial citizenship
to emigrants is not part of a coherent understanding of cross-national membership and
citizenship that is equal for all. As Vink and Bauböck (2010) correctly assess, citizenship
laws regulate not only immigrant inclusion, but may pursue different purposes. Our study
exemplifies how citizenship laws regulate rights of emigrants and is relevant for studies
on the motivations behind policies of countries origin to undertake citizenship reforms
towards their emigrants, since many authors hypothesize that countries which allow dual
nationality to their diasporas put aside earlier fears of divided loyalty in the hope to achieving
a number of goals, from encouraging remittances, to developing a lobby in the receiving
countries. Our analysis suggests that dual nationality can be quite nuanced to achieve such
ends and that these nuances should be studied for other countries. Across LAC, the loyalty
of the naturalized is continually questioned, reflecting a sense that their links to the nation
and the political community have primarily been established through residence, and are
therefore more fragile to breakage after emigration than the links of nationals by origin.
Such discriminatory treatment regarding the portability of citizen rights and exclusivity
of belonging of nationals by naturalization suggests that many countries still attribute to
immigrants of the very fears they are supposed to have overcome for their own nationals.
In a third and contrasting sense, the old historical understanding of what constitutes a
proper linkage of an individual to a community surfaces in some countries where citizen
rights are deactivated upon residence abroad, and recoverable upon residence again in the
country. It echoes a fundamental dissociation that goes back to the core of other citizenship
understandings, beyond (or before) nationality (Pedroza 2012). Some of the countries show-
cased revealed to have a strong connection to a citizenship anchored primarily in residence
as proof of a strong and present link to the community of deciding people.

Notes
1. 
We understand nationality as the legal relation of membership between an individual and a
nation state; source of (traditionally exclusive) rights/obligations between the two (i.e. not
human rights which are enjoyed irrespective of nationality); usually only acquired by birth
or by naturalization; and attestable through birth certificates or travel documents (passport).
 CITIZENSHIP STUDIES   601

We understand citizenship as the entitlement (the condition of having a right) to exercise

formal civic rights and duties within a political community.
2.  In his study of nationality laws in the Western Hemisphere, Vonk uses the terms interchangeably,
arguing that his focus is the English-speaking world, for which the differentiation is
superfluous, and that he follows empirical indicators developed by the EUDO Citizenship
Observatory. While we understand these reasons, it is key to note that this distinction is
consequential for migrants and other groups who are seemingly trapped in in-between
categories, such as the naturalized).
3.  See Gosewinkel (2001) for relation between nationality and citizenship in the USA.
4.  The other six do not: Trinidad and Tobago, Jamaica, Belize, Brazil, Ecuador and Cuba.
5.  Also taking into account a regional and even transnational (multifocal) reading of citizenship
historical developments in Latin America, Sznajder and Roniger (2009) have shown how this
tension crystallized in exile, a situation which deprived those beyond the borders of their
political rights, but not of voice, as it was precisely in exile that many displaced nationals
invented the ‘collective soul’ of the nation. Similarly, thinking about both exile and the politics
of transnational migration, Hoffmann (2010) suggests that the Hirschmanian categories of
exit, voice and loyalty are not mutually exclusive, but may be simultaneous and overlapping.
6.  The contrast that we are able to make with Caribbean countries, well immerse in the geography,
yet part other colonial legal traditions, supports this interpretation.
7.  We are aware that a meaningful understanding of the actual range of rights that can be
exercised abroad (i.e. their portability) requires considering electoral rights, but we see this
as a second step, which must be preceded by a proper understanding of the distinctions made
between citizenship and nationality as an enabling condition to exercise citizen rights (see
Palop-García and Pedroza 2016).
8.  The Dominican Constitutional Court ruled in 2013 that children born in the Dominic Republic
to undocumented residents ought not to be considered Dominican nationals. It is estimated
that this ruling affected more than 250,000 Dominicans (Gamboa and Harrington 2014).
This, however, is not related directly to our object of study since that denial of nationality
did not derive from the adoption of another foreign nationality, but from the administrative
situation of the parents of Dominican born persons with Haitian ancestry.
9.  In 2011, the conditions enrol in the civil registry and prove residence (as to acquire legal
citizenship) were facilitated by Law 18.858 and in 2016 Law 19.362 made it possible for
Uruguayans abroad to pass on nationality to a third generation. However, citizenship is still
only acquired if they establish residence in Uruguay.
10. Honourable Cámara de Diputados de la Nación, Ley N° 346 – Ciudadanía Y Naturalización,
2004, Art. 8.
11. Dirección Nacional de Migraciones, Resolución No 2.650, Anexo II, 1c.
12. Interestingly, contemporary Spain makes no differentiation between citizenship and
nationality, yet it has a dormant nationality clause in its treaties of with Latin American
states – e.g. Convenio de Nacionalidad entre España y Colombia 1980; Convenio sobre Doble
Nacionalidad entre España y Perú 1960.
13. It might strike some readers that Uruguayan and Argentine emigrants who are non-residents
in the former case, and dual nationals in the second, still exercise their right to vote. This
is, however, the result of incoherence between legal regulations (which is what we studied
and coded) and (lack of) implementation likely due to the complication of the procedure to
enforce them. For Argentina such procedure is explained in the Decreto sobre ciudadanía y
naturalización 3.213/1984, Arts. 15–17.
14. Both components have the same weight (50%). The final indicator ranges from 0 to 1, being
0 the more restrictive regulation and 1 the more inclusive.

Disclosure statement
No potential conflict of interest was reported by the authors.
602   L. PEDROZA AND P. PALOP-GARCÍA

Funding
This work was supported by the Deutsche Forschungsgemeinschaft.

References
Aleinikoff, Alexander, and Douglas Klusmeyer. 2001. “Plural Nationality: Facing the Future in a
Migratory World.” In Citizenship Today: Global Perspectives and Practices, edited by Alexander
Aleinikoff and Douglas Klusmeyer. Washington, DC.
Annino, Antonio, Lúcia Maria Bastos, P. Neves, and Marco Bellingeri, eds. 1995. Historia de Las
Elecciones En Iberoamérica, Siglo XIX. De La Formación Del Espacio Político Nacional. Buenos
Aires: Fondo de Cultura Económica Sección de Obras de Historia.
Asamblea Nacional Constituyente. 1949. Constitución Política de Costa Rica. http://pdba.georgetown.
edu/Parties/CostaRica/Leyes/constitucion.pdf.
Barbulescu, Roxana. 2011. “Multiple Philosophies of Integration: Policies for Immigrant Integration
in Spain and Italy.” In ECPR General Conference, Reykjavik.
Bauböck, Rainer. 2007. “Stakeholder Citizenship and Transnational Political Participation: A
Normative Evaluation of External Voting.” Fordham Law Review 75 (5): 2393–2447.
Bauböck, Rainer. 2009. “The Rights and Duties of External Citizenship.” Citizenship Studies 13 (5):
475–499.
Bauböck, Rainer. 2010. “Studying Citizenship Constellations.” Journal of Ethnic and Migration Studies
36 (5): 847–859.
Bauböck, Rainer. 2015. “Morphing the Demos into the Right Shape. Normative Principles for
Enfranchising Resident Aliens and Expatriate Citizens.” Democratization 22 (5): 820–839.
Blatter, Joachim. 2011. “Dual Citizenship and Theories of Democracy.” Citizenship Studies 15 (6–7):
769–798.
Cantor, David James, Luisa Feline Freier, and Jean-Pierre Gauci, eds. 2015. A Liberal Tide? Immigration
and Asylum Law and Policy in Latin America. London: ILAS, University of London.
Carmagnani, Marcello, and Alicia Hernández Chávez. 1999. “La Ciudadanía Orgánica Mexicana,
1850–1910.” In Ciudadanía Política Y Formación de Las Naciones: Perspectivas Históricas de América
Latina, 371–404. México: Fondo de Cultura Económica.
Cohen, Elizabeth F. 2009. Semi-Citizenship in Democratic Politics. Cambridge: Cambridge University
Press.
Collyer, M. 2014. “A Geography of Extra-territorial Citizenship: Explanations of External Voting.”
Migration Studies 2 (1): 55–72.
Collyer, Michael. 2013. Emigration Nations: Policies and Ideologies of Emigrant Engagement.
Basingstoke: Palgrave Macmillan.
Congreso de la Unión. 1917. Constitución Política de Los Estados Unidos Mexicanos. http://www.
diputados.gob.mx/LeyesBiblio/htm/1.htm.
Convención Nacional Constituyente. 1992. Constitución de La República Del Paraguay. http://www.
bacn.gov.py/CONSTITUCION_ORIGINAL_FIRMADA.pdf.
Convenio de Nacionalidad Entre Espana Y Colombia. 1980. Boletín Oficial Del Estado. Vol. 287.
Convenio Sobre Doble Nacionalidad Entre Espana Y Perú. 1960. Boletín Oficial Del Estado. Vol. 5625.
del Castillo Velasco, José María. 1875. Ensayo Sobre El Derecho Administrativo Mexicano. México:
Impr. de la Escuela de artes y oficios para mujeres.
Delano, Alexandra. 2009. “Immigrant Integration vs. Transnational Ties? The Role of the Sending
State.” SSRN Scholarly Paper ID 1452219. Rochester, NY: Social Science Research Network.
Dirección Nacional de Migraciones. 1984. Resolución No 2.650. Apruébase El Cuerpo de Instrucciones
Para El Tratamiento Migratorio de Los Argentinos Que Se Hubieran Naturalizado En Otro País.
http://infoleg.mecon.gov.ar/infolegInternet/anexos/160000-164999/162202/norma.htm.
Dugard, John. 2006. International Law. A South African Perspective. 3rd ed. Cape Town: Juta.
Escobar, Cristina. 2007. “Extraterritorial Political Rights and Dual Citizenship in Latin America.”
Latin American Research Review 42 (3): 43–75.
 CITIZENSHIP STUDIES   603

Escobar, Cristina. 2015. “Immigrant Enfranchisement in Latin America: From Strongmen to Universal
Citizenship.” Democratization 22 (5): 927–950.
Faist, Thomas. 2001a. “Dual Citizenship as Overlapping Membership.” http://dspace.mah.se/dspace/
handle/2043/691.
Faist, Thomas. 2001b. “Jenseits von Nation Und Post-nation. Transstaatliche Räume Und Doppelte
Staatsbürgerschaft.” Zeitschirft Für Internationale Beziehungen 7 (1): 109–144.
Faist, Thomas, and Peter Kivisto, eds. 2007. Dual Citizenship in Global Perspective. Basingstoke:
Palgrave Macmillan.
Fox, Jonathan. 2005. “Unpacking ‘Transnational Citizenship’*.” Annual Review of Political Science 8
(1): 171–201.
Gamboa, Liliana, and Julia Harrington. 2014. “Desnacionalización Judicial de Las Personas
Dominicanas de Ascendencia Haitiana.” Revista Migraciones Forzadas, no. 46: 52–54.
Gamlen, Alan. 2014. “Diaspora Institutions and Diaspora Governance.” International Migration
Review 48 (1): S180–S217.
Ginsburg, Tom, and Rosalind Dixon, eds. 2011. Comparative Constitutional Law. Chicago, IL: Edward
Elgar Pub.
Gosewinkel, Dieter. 2001. “Citizenship, Subjecthood, Nationality: Concepts of Belonging in the Age
of Modern Nation States.” In European Citizenship between National Legacies and Postnational
Projects, 17–35. Oxford: Oxford University Press.
Guarnizo, Luis Eduardo, Alejandro Portes, and William Haller. 2003. “Assimilation and
Transnationalism: Determinants of Transnational Political Action among Contemporary Migrants.”
American Journal of Sociology 108 (6): 1211–1248.
Guerra, Francois-Xavier. 1999. El Soberano Y Su Reino. Reflexiones Sobre La Génesis Del Ciudadano
En América Latina. México: El Colegio de México.
Hammar, Thomas. 1985. “Dual Citizenship and Political Integration.” International Migration Review
19 (3): 438–450.
Herzog, Tamar. 2007. “Communities Becoming a Nation: Spain and Spanish America in the Wake
of Modernity (and Thereafter).” Citizenship Studies 11 (2): 151–172.
Ballin Hirsch, Ernst. 2014. Citizens’ Rights and the Right to Be a Citizen. Leiden: Brill Nijhoff.
Hoffmann, Bert. 2010. “Bringing Hirschman Back in: ‘Exit’, ‘Voice’, and ‘Loyalty’ in the Politics of
Transnational Migration.” The Latin Americanist 54 (2): 57–73.
Honorable Cámara de Diputados de la Nación. 2004. Ley N° 346 – Ciudadanía Y Naturalización.
Argentina.  Dirección de información parlamentaria. Buenos Aires http://www1.hcdn.gov.ar/
dependencias/dip/textos%20actualizados/346-240805.pdf. Accessed April 10, 2017.
Hoyo, Henio. 2015. “Apertura Externa, Exclusión Interna: El Nacionalismo Revolucionario Y
Los Derechos de Migrantes, Mexicanos Por Naturalización, Y Doblres Nacionales En México.”
desiguALdades.net Working Paper, no. 87.
Irurozqui, Marta. 1996. “La Ciudadanía En Debate En América Latina. Discusiones Historiográficas
Y Una Propuesta Teórica Sobre El Valor Público de La Infracción Electoral.” Edited by IEP, no. 139.
Itzigsohn, Jose. 2000. “Immigration and the Boundaries of Citizenship: The Institutions of Immigrants
Political Transnationalism.” International Migration Review 34 (4): 1126–1154.
Jones-Correa, Michael. 2001. “Under Two Flags: Dual Nationality in Latin America and Its
Consequences for Naturalization in the United States.” International Migration Review 35 (4):
997–1029.
Joppke, Christian. 2005. Selecting by Origin. Ethnic Migration in the Liberal State. Cambridge, MA:
Harvard University Press.
La Constitución de La Republica de Ecuador de. 2008.
Lafleur, Jean-Michel. 2005. Le transnationalisme politique. Pouvoir des communautés immigrées dans
leurs pays d’accueil et pays d’origine. Louvain-la-Neuve: Academia Bruylant.
Las Cortes Generales y Extraordinarias de la Nación. 1812. Constitución Política de La Monarquía
Espanola Promulgada En Cádiz En Marzo de 1812.
Law Revision Commissioner. 2000. Belizean Nationality Act Chapter 161.
604   L. PEDROZA AND P. PALOP-GARCÍA

León, Pablo Sandonato de. 2007. “Nacionalidad Y Extranjería En El Uruguay, Un Estudio Normo-
Político.” Jurídica: Anuario Del Departamento de Derecho de La Universidad Iberoamericana 37:
435–462.
Martiniello, Marco, and Jean-Michel Lafleur. 2008. “Towards a Transatlantic Dialogue in the Study
of Immigrant Political Transnationalism.” Ethnic and Racial Studies 31 (4): 645–663.
Mazzolari, Francesca. 2009. “Dual Citizenship Rights: Do They Make More and Richer Citizens?”
Demography 46 (1). http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2831260/.
Naujoks, Daniel. 2012. “India and Its Diaspora. Changing Research and Policy Paradigms.” In National
Paradigms of Migration Research, edited by Dietrich Thränhardt and Michael Bommes, 269–300.
Göttingen: V&R unipress.
Nohlen, Dieter, and Florian Grotz. 2007. “The Legal Framework and an Overview of Electoral
Legislation.” Draft Chapter for International IDEA: E Xternal Voting Handbook. http://www.idea.
int/publications/voting_from_abroad/upload/chap3.pdf.
Østergaard-Nielsen, Eva. 2003. “The Politics of Migrants’ Transnational Political Practices.”
International Migration Review 37 (3): 760–786.
Oyarzábal, Mario. 2003. La Nacionalidad Argentina: Un Estudio Desde La Perspectiva Del Derecho
Internacional Público, Del Derecho Internacional Privado Y Del Derecho Interno Argentino, Con
Referencias Al Derecho de La Integración. Buenos Aires: La Ley.
Levitt, Peggy. 2001. “Transnational Migration: Taking Stock and Future Directions.” Global Networks
1 (3): 195–216.
Palop-García, Pau, and Luicy Pedroza. 2016. “Beyond Convergence: Unveiling Variations of External
Franchise in Latin America and the Caribbean from 1950 to 2015.” Journal of Ethnic and Migration
Studies, September, 1–20. doi:10.1080/1369183X.2016.1234932.
Pedroza, Luicy. 2012. “Citizenship before Nationality. How Liberal Democracies Redefine Citizenship
by Extending Voting Rights to Resident Migrants.” PhD Dissertation, University of Bremen.
Poder Legislativo. 1967. Constitución de La República de Uruguay. http://www.parlamento.gub.uy/
constituciones/const004.htm.
Portes, Alejandro, Luis E. Guarnizo, and Patricia Landolt. 1999. “The Study of Transnationalism:
Pitfalls and Promise of an Emergent Research Field.” Ethnic and Racial Studies 22 (2): 217–237.
Quiroga Lavié, Humberto. 1991. “Los Presupuestos Básicos Para La Organización Del Estado En
Latinoamérica.” In Derecho Constitucional Latinoamericano, edited by Estudios Comparativos and
Derecho Latinoamericano 28. México: Universidad Nacional Autónoma de México.
Ragazzi, Francesco. 2014. “A Comparative Analysis of Diaspora Policies.” Political Geography 1–16: doi:
10.1016/j.polgeo.2013.12.004.
Sábato, Hilda. 1999. Ciudadanía Política Y Formación de Las Naciones: Perspectivas Históricas de
América Latina. México: Fondo de Cultura Económica.
Schlenker, Andrea. 2015. “Divided Loyalty? Identification and Political Participation of Dual Citizens
in Switzerland.” European Political Science Review FirstView Article (August): 1–230.
Schuck, Peter. 2002. “Plural Citizenships.” In Dual Nationality, Social Rights and Federal Citizenship in
the U.S. and Europe, edited by Randall Hansen and Patrick Weil, 61. New York: Berghahn Books.
Scott Fitzgerald, David, and David Cook Martin. 2015. Culling the Masses. The Democratic Origins of
Racist Immigration Policy in the Americas. Cambridge, MAHarvard University Press.
Spiro, P. J. 2010. “Dual Citizenship as Human Right.” International Journal of Constitutional Law 8
(1): 111–130.
Sznajder, Mario, and Luis Roniger. 2009. The Politics of Exile in Latin America. Cambridge: Cambridge
University Press.
Vink, Maarten, and Rainer Bauböck. 2013. “Citizenship Configurations: Analysing the Multiple
Purposes of Citizenship Regimes in Europe.” Comparative European Politics. http://www.
migrationpolicycentre.eu/docs/SummerSchool2013/readings/Baubock%20-%20Reading.pdf.
Vink, Maarten Peter. 2013. “Immigrant Integration and Access to Citizenship in the European Union:
The Role of Origin Countries.” EUI RSCAS.
Vink, Maarten Peter, and G. R. De Groot. 2010. “Citizenship Attribution in Western Europe:
International Framework and Domestic Trends.” Journal of Ethnic and Migration Studies 36 (5):
713–734.
 CITIZENSHIP STUDIES   605

Vonk, Olivier Willem. 2014. Nationality Law in the Western Hemisphere. A Study on Grounds of
Acquisition and Loss of Citizenship in the Americas and the Caribbean. Leiden: Martinus Nijhoff.
Wollny, Hans. 1991. “Asylum Policy in Mexico: A Survey.” Journal of Refugee Studies 4 (3): 219–236.