Multi-Generational Citizenship Planning: Securing Options for Your Children and Grandchildren

Most citizenship planning conversations focus on the individual: which programme, which investment, which passport. Multi-generational citizenship planning asks a different and in some respects more important question: what options will your children and grandchildren have, and what decisions made now will constrain or expand those options decades from now?

For wealthy internationally mobile families, this question is particularly acute. Children may be born in different countries, educated in others, and build their professional lives in yet others. A citizenship portfolio that serves the current generation may inadvertently create complications — or forfeited opportunities — for the next.

The Two Fundamental Principles: Jus Soli and Jus Sanguinis

Citizenship acquisition from birth is governed by two principles that operate very differently:

Jus soli ("right of the soil") confers citizenship on the basis of being born within a country's territory, regardless of the parents' nationality. The United States is the most significant example among developed nations. Canada also applies jus soli. In both countries, birth on national territory — including for children of non-citizen parents — automatically confers citizenship of that country.

Jus sanguinis ("right of blood") confers citizenship on the basis of descent from a citizen parent, regardless of where the child is born. Most European countries operate primarily on jus sanguinis principles. The UK, Germany, Italy, France, Ireland, and most of the Commonwealth are predominantly jus sanguinis systems.

Many countries operate a combination of both, and the specific rules — particularly regarding children born abroad to citizen parents — vary significantly in the details.

The UK Citizenship-by-Descent Transmission Limit: A Critical Planning Point

British citizenship contains a rule that is not widely understood but which has significant planning implications for internationally mobile British families:

British citizenship by descent (Section 2, British Nationality Act 1981) can be passed to children born abroad, but it cannot be passed to grandchildren born abroad through that same line of descent.

In practical terms: a British citizen who was born abroad to a British parent (and who is therefore themselves a British citizen "otherwise than by descent") can transmit British citizenship to their own children born abroad. However, those children — themselves British citizens by descent — cannot automatically transmit British citizenship to their children if those grandchildren are also born abroad.

This means that a British family living permanently abroad may find that:

• Generation 1 (grandparents): British citizens by birth in the UK — full transmission rights
• Generation 2 (parents): British citizens by descent, born abroad — can transmit to their children
• Generation 3 (children): British citizens by descent, born abroad — cannot transmit to their own children unless those children are born in the UK, or additional registration steps are taken

The mechanism for breaking this chain — registering the second-generation-born-abroad child in the UK before age 18 under section 3(2) or 3(5) of the British Nationality Act — is available but requires an active application and approval by the Home Office. This registration, once obtained, upgrades the child's status to "otherwise than by descent" and restores full transmission rights.

For British expatriate families — particularly those who have been abroad for multiple generations, or who plan to remain abroad permanently — the practical consequence is that without deliberate action before the second-generation child's birth or during their childhood, British citizenship can be lost for subsequent generations.

Ireland: The Most Valuable Citizenship by Descent in Europe

By contrast, Irish citizenship by descent has historically been one of the most generous in Europe. An individual with at least one Irish-born grandparent can claim Irish citizenship through the Foreign Births Register, even if their parents never obtained it. This three-generation reach makes Irish citizenship by descent a significant planning asset for families with Irish heritage, particularly post-Brexit, as Irish citizenship confers full EU citizenship.

Ireland has in recent years introduced waiting times for Foreign Births Register processing (backlogs of two to three years have been reported as of 2026), but the underlying entitlement remains. For families aware of an Irish grandparent's birth, applying to register as a Foreign Birth is a high-value administrative task that should not be indefinitely deferred.

Caribbean CBI Citizenship: Passing to Future Generations

Caribbean CBI citizenship, once obtained, passes by descent in the same way as any other citizenship of that country. A Grenadian citizen passes Grenadian citizenship to their children born anywhere in the world, subject to Grenada's own jus sanguinis rules. Unlike a Golden Visa or residency programme, citizenship is permanent and inheritable.

This characteristic makes Caribbean CBI citizenship particularly valuable from a multi-generational perspective. A parent who acquires Grenadian citizenship today secures not only their own Schengen and UK visa-free access, and potentially E-2 treaty access to the US for themselves, but also those rights for their descendants — indefinitely.

The inclusion of dependent children in a CBI application is standard practice across all Caribbean programmes. Minor children can be included in the same application as the main applicant, at a supplementary cost, with no additional investment required. Adult children over 18 typically require their own investment contribution or can be added as dependants at higher cost depending on programme rules.

Trust Structures and Property-Based Residency: Passing to the Next Generation

Some residency-by-investment programmes are structured around property ownership. The Portuguese Golden Visa (in its previous property-investment form), the Greek Golden Visa, and similar schemes provided residency rights to the owner of qualifying property. When that property is held in a trust or family holding structure rather than directly, the question of succession becomes important.

Residency rights in these programmes are typically tied to the named investment vehicle, not to the property title per se. If a trust holds the qualifying property:

• The settlor (original investor) may hold residency, but beneficiaries do not automatically acquire it
• Transfer of beneficial interest to the next generation upon death may not automatically transfer residency rights
• Some programmes require reapplication or updated registration when ownership changes hands

A family foundation can in some jurisdictions be structured as the qualifying investment vehicle, with multiple family members named as beneficiaries, each holding residency. This approach — common in Austrian, Liechtenstein, and Maltese contexts — requires careful structuring and local legal advice in the relevant jurisdiction.

For citizenship (rather than residency), once obtained it is permanent and does not depend on continued property ownership. This is a fundamental distinction: citizenship is a permanent status; residency is contingent on continued compliance with programme conditions (investment maintenance, physical presence, etc.).

Birthright Citizenship: The US Jus Soli Option

The United States' jus soli rule means that any child born on US soil is a US citizen, regardless of the parents' immigration or citizenship status. This rule, established by the 14th Amendment to the US Constitution, has been a significant planning consideration for non-US HNW families who want to secure US citizenship for their children.

The practical implications of US citizenship should, however, be understood fully before treating a US birth as a planning benefit:

Citizenship-based taxation: The United States taxes its citizens on their worldwide income regardless of where they live. A child born in the US to non-US parents and who subsequently lives entirely outside the United States remains subject to US tax filing obligations for life — including FBAR, FATCA, and all associated compliance burdens — unless they formally renounce US citizenship. This is an ongoing cost, not a one-time event.

FATCA and banking: US citizens living abroad face significant difficulties with banking and financial services, because financial institutions that serve US persons have extensive FATCA reporting obligations. Many non-US banks have reduced or eliminated services to US persons as a result.

Renunciation is difficult and costly: The formal renunciation of US citizenship requires an appointment at a US consulate, payment of a renunciation fee (reduced to USD 450 from 12 April 2026, having previously stood at USD 2,350), potential exit tax on accumulated wealth, and an IRS compliance review. The fee is no longer the dominant cost — the exit tax and compliance review are the substantive considerations — and the State Department has significant backlogs for renunciation appointments in many cities.

For families who are primarily US-based and US-connected, these considerations are largely moot — US citizenship is an asset, not a liability. For families who are primarily internationally mobile with no particular US connection, the acquisition of US citizenship for children born during a US visit should be considered thoughtfully.

Education Jurisdiction for Children

Where children attend school and university matters for citizenship planning in two respects:

Long-term residency accumulation: Children who attend school in a country for several years may qualify for naturalisation by long residence in adulthood. In the UK, continuous residence (including school years) counts towards naturalisation eligibility. In Germany, children who are born in Germany to long-term residents are entitled to German citizenship. This means that the decision about where to educate children is also, indirectly, a decision about which citizenship options they may accumulate.

Future student visa requirements: Children who do not hold a second citizenship may face student visa requirements in the country of their chosen university. Planning a second citizenship earlier in a child's life eliminates this complication and may also open up fee entitlements (EU tuition fee rates for EU citizens, for example).

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This guide reflects citizenship laws as understood in mid-2026. Nationality laws are complex, frequently amended, and interpreted differently by individual countries' home offices and courts. The points about the British citizenship-by-descent limit and Irish Foreign Births Register reflect current general understanding but must be verified with an immigration solicitor before relying on them. Nothing in this guide constitutes legal advice.

How Global Investments Can Help

Global Investments advises internationally mobile families on building citizenship portfolios that serve multiple generations. We help families identify existing entitlements — including descent claims and registration opportunities — and plan investment-based citizenship acquisitions that strengthen the family's long-term position. Our approach integrates citizenship planning with estate planning, trust structuring, and property investment to ensure that your family's mobility and options are protected for decades to come. Contact us to arrange a family planning consultation.