Last updated: November 12, 2026
Since June 27, 2024, Germany accepts dual citizenship. Thousands of Canadians and Americans have since confirmed or regained German citizenship. With the second passport come practical questions that nobody explains at the consulate: which passport at which border, who owes taxes where, what happens to the old German address and whether men have to serve. This guide collects the answers for German Canadian and German American dual citizens in 2026 and links to our detailed articles.
TL;DR
- Fly to Canada on the Canadian passport, enter and leave the US on the US passport, enter Germany on the German passport or ID card.
- US citizens must file US tax returns wherever they live. Germany and Canada tax by residence, not by citizenship.
- Moving away from Germany? De-register within two weeks after moving out.
- Military service in Germany is voluntary. Stays abroad by men aged 17 to 45 are deemed approved.
- Children born abroad: if the German parent was also born abroad after 1999, register the birth within one year.
Is dual citizenship allowed?
Germany: yes, since June 27, 2024. Acquiring a foreign citizenship no longer costs you German citizenship, and you do not have to give up a foreign citizenship to become German. The change does not apply retroactively. Canada and the United States also allow dual citizenship. Details in Does Germany allow dual citizenship with Canada?
Lost German citizenship before 2024 by becoming Canadian or American? Read regaining German citizenship.
Which passport should a dual citizen use?
Each country expects its own citizens to present its own document. Canada requires Canadian dual citizens to carry a valid Canadian passport when returning by air, even when only passing through. The US requires US nationals, including dual nationals, to use a US passport to enter and leave the United States. Germany lets its citizens enter with a German passport or ID card.
| Trip | Which passport | Why |
|---|---|---|
| Flying to or through Canada as a Canadian dual citizen | Canadian passport | Canada requires its citizens to carry a valid Canadian passport when returning by air. A special authorization is possible in limited cases |
| Entering or leaving the United States as a US dual citizen | US passport | US law requires US nationals, including dual nationals, to use a US passport |
| Entering Germany or the Schengen area | German passport or German ID card | As a German you have a right of entry. The 90 day limit for visitors does not apply to you |
| Leaving Germany for Canada | German document at German border control, Canadian passport at check-in | Airlines check whether you may enter the destination country |
| Travelling to a third country | The passport with better entry conditions | Use the same passport for entry and exit of that country |
A German passport for adults aged 24 and over is valid for ten years, for younger people six years. Apply early at the German mission responsible for your province. How to get your first German passport is explained in How to get a German passport.
Taxes: who taxes what
- Germany taxes income of people who have their residence or habitual abode in Germany. Citizenship alone does not create German income tax liability. Income from German sources, such as rent from a German apartment, can still be taxable in Germany.
- Canada also taxes by residence. Canadian citizens who live abroad and have cut residential ties are generally not taxed on foreign income.
- The United States taxes its citizens wherever they live. US citizens in Canada or Germany must file a US return if their income exceeds the filing threshold. The foreign earned income exclusion for 2026 is 132,900 US dollars. Foreign accounts above 10,000 US dollars in total at any time in the year must be reported to FinCEN (FBAR). Foreign tax credits and the tax treaties usually prevent double taxation, but not the filing obligation.
Inheritances follow their own rules, see German inheritance tax allowances.
De-registration in Germany
Anyone who moves abroad and gives up their residence in Germany must de-register (Abmeldung) within two weeks after moving out. Forgetting it can result in a fine of up to 1,000 euros and can create problems with tax residence, health insurance and broadcasting fees. What to do if you left without de-registering is explained in Forgot to de-register in Germany?
Descendants who confirm their German citizenship from Canada and have never lived in Germany are not affected.
Military service
Germany amended its military service law with effect from January 1, 2026. Service remains voluntary, there is no general conscription. The amendment caused confusion because men aged 17 to 45 need approval for stays abroad of more than three months. A general ruling published on April 9, 2026 clarified that such stays are deemed approved as long as compulsory military service is suspended. Acquiring or confirming German citizenship has no consequences under military service law at present. Details in Staying abroad for men of military age.
Children of dual citizens
Children of a German parent are usually German by birth, wherever they are born. For children born abroad, there is one trap: if the German parent was also born abroad after December 31, 1999 and lives abroad, the child only becomes German if the birth is registered with the German registry office within one year. Read German citizenship of children.
Voting from abroad
Germans abroad can vote in federal elections if they lived in Germany for at least three months without interruption after turning 14 and that was no more than 25 years ago, or if they are personally and directly familiar with political conditions in Germany. You have to apply for entry in the electoral register before each election.
Questions about your situation as a dual citizen? Book a consultation with our German lawyers in Calgary or call us at +1 587 349 3535.
Frequently asked questions
Which passport should I use if I am German and Canadian?
Use the Canadian passport to fly to Canada and the German passport or ID card to enter Germany and the Schengen area. At check-in for a flight to Canada, show the Canadian passport.
Do US citizens living in Canada or Germany have to file US taxes?
Yes. The United States taxes its citizens on worldwide income regardless of where they live. Whether a return is required depends on income thresholds. The foreign earned income exclusion for 2026 is 132,900 US dollars, and foreign accounts above 10,000 US dollars in total must be reported.
Do I pay German income tax because I am German?
No. German income tax depends on residence or habitual abode in Germany, not on citizenship. A German citizen who lives only in Canada is generally not subject to unlimited German income tax.
Do I have to de-register in Germany when I move to Canada?
Yes. If you move abroad and give up your German residence, you must de-register within two weeks after moving out. Missing this can lead to a fine and to problems with taxes and health insurance.
Do German men in Canada have to do military service?
No. Military service in Germany is voluntary. Since a general ruling of April 9, 2026, stays abroad by men aged 17 to 45 are deemed approved as long as compulsory service is suspended.
Can I lose German citizenship if I become Canadian or American?
Not anymore. Since June 27, 2024, acquiring a foreign citizenship no longer leads to the loss of German citizenship. Anyone who lost it before that date can apply for re-naturalization.
Can I vote in German elections from Canada?
Germans abroad can vote in federal elections if they lived in Germany for at least three months after turning 14 and moved away no more than 25 years ago, or if they are personally and directly familiar with political conditions in Germany. You have to apply for registration before each election.
Sources
- Government of Canada: Dual citizenship
- U.S. Department of State: Dual nationality
- IRS: Foreign earned income exclusion
- FinCEN: Report of foreign bank and financial accounts (FBAR)
- Section 17 Federal Registration Act (BMG)
- Section 12 Federal Elections Act (BWahlG)
This article is for general information only and does not replace individual legal or tax advice. Rocky Mountain German Law Ltd., Suite 201, 8989 Macleod Trail S.W., Calgary, AB.
