The intersection of global citizenship, extraterritorial taxation, and constitutional requirements for state leadership is frequently misunderstood. A prominent example is the speculative claim from British commentators that former UK Prime Minister Boris Johnson could theoretically cross the Atlantic to run for the presidency of the United States. While rooted in the fact of his New York birth, this scenario collapses under the structural mechanics of international tax compliance and the legal reality of citizenship renunciation.
Citizenship by Soil vs. Citizenship by Blood
The legal foundation of global nationality generally follows two distinct doctrines: jus soli (right of the soil) and jus sanguinis (right of the blood).
- The New World Framework (Jus Soli): The United States, Canada, and nearly all nations in the Americas grant automatic citizenship to anyone born on their physical territory, regardless of the parents’ nationalities. Boris Johnson was born in New York and lived there for the first five years of his life, which legally designated him a U.S. citizen by virtue of birth.
- The Old World Framework (Jus Sanguinis): In contrast, acquiring British or European citizenship historically relies on lineage. Being born within the geographical borders of the UK does not automatically grant nationality; an individual must be born to at least one British parent. Johnson held dual citizenship because he inherited British nationality from his parents while simultaneously holding U.S. citizenship via jus soli.
The Financial Dragnet of Extraterritorial Taxation
The primary complication of maintaining U.S. citizenship while living long-term as an expatriate is America’s strict implementation of citizenship-based taxation.
Unlike nearly every other nation, which taxes individuals based on physical residence, the United States levies taxes on the worldwide income of its citizens, regardless of where they live, earn, or hold bank accounts.
GLOBAL TAXATION MECHANISMS: RESIDENCY VS. CITIZENSHIP
[Standard Global System] ──► Taxation Based Solely on Domicile / Physical Residence
[United States System] ──► Extraterritorial Taxation on Worldwide Income via Passport
The Accidental American Penalty
Many individuals born in the U.S. who relocate as children are classified as “Accidental Americans.” They remain fully liable to file annual federal returns with the IRS. While double taxation can often be mitigated or eliminated for entrepreneurs and employees through international tax treaties, structural issues emerge regarding capital gains on primary assets.
The Boris Johnson Tax Precedent
In the mid-2010s, while serving as the Mayor of London, Johnson sold his primary personal residence in the United Kingdom. Under UK tax law, the sale of a primary home is completely exempt from capital gains tax. However, because the capital gains exceeded standard U.S. expat exclusions, the IRS issued a substantial tax bill.
Despite public protests that he had not lived in the United States since the age of five, Johnson was legally required to settle his tax compliance liabilities with the IRS. To permanently insulate his global earnings from further U.S. extraterritorial reach, he executed a formal renunciation of his U.S. citizenship, with his name subsequently appearing on the quarterly Federal Register of expatriated individuals.
Presidential Eligibility and Former Citizens
The structural barrier preventing a figure like Boris Johnson from seeking the U.S. presidency is not his historical timeline of foreign residence, but his absolute lack of status as an active U.S. citizen.
The Natural-Born Misconception
Article II of the U.S. Constitution stipulates that a presidential candidate must be a “natural-born citizen.” A common misconception is that this definition is strictly limited to individuals born within the 50 states.
Historical political precedents demonstrate a wider legal interpretation:
- John McCain (2008): Born on a U.S. military installation within the Panama Canal Zone to American parents, McCain was widely recognized as a natural-born citizen because he inherited citizenship at birth rather than undergoing a later naturalization process.
- Ted Cruz (2016): Born in Calgary, Canada, to an American mother, Cruz initially held dual Canadian-U.S. citizenship before formally renouncing his Canadian status. His eligibility to run was protected because he was an American citizen from the moment of birth.
- The Naturalized Prohibition: Conversely, naturalized individuals who acquired citizenship later in life (such as former California Governor Arnold Schwarzenegger or former Secretary of State Henry Kissinger) are permanently barred from the presidency.
The Finality of Renunciation
Because Boris Johnson voluntarily relinquished his U.S. nationality via a formal Certificate of Loss of Nationality (CLN), he is legally classified as an alien relative to the United States. He cannot execute standard civic rights, let alone seek the highest political office.
To theoretically re-establish a pathway, a former natural-born citizen would have to apply for entry like any other foreign national—such as deploying at-risk capital through the EB-5 investment visa program or demonstrating exceptional capacity via an O-1 visa—and undergo standard naturalization. However, once an individual voluntarily renounces their birthright citizenship, they permanently forfeit their constitutional status as a natural-born American.
Dual Citizenship Restrictions Globally
While the United States permits its citizens to hold multiple passports, political candidates are frequently forced to shed foreign citizenships to establish baseline domestic credibility. Candidates such as Ted Cruz and Michelle Bachmann (who held Swiss citizenship by marriage) executed formal renunciations of their secondary nationalities as explicit political statements during their respective campaigns.
In alternative constitutional structures, the cross-over of foreign nationalities can completely disrupt a political career:
- The Armenia Precedent: In certain nations like Armenia, the constitution allows naturalized citizens to seek office. However, a former President of Armenia faced significant domestic challenges and ultimately resigned after investigations revealed he held citizenship by investment from St. Kitts and Nevis too close to his ascension to the presidency.
- The Dr. Oz Precedent: During his campaign for the U.S. Senate, candidate Mehmet Oz faced intense scrutiny for holding dual U.S. and Turkish citizenship, illustrating that voters routinely look less favorably upon dual nationality involving complex geopolitical states than traditional Western nations.
The Expat Lesson: U.S. citizenship functions as a rigid legal and financial web that follows an individual globally until it is formally severed. Entrepreneurs looking to establish international structures must utilize vetted international CPAs and specialized legal counsel to maintain structural compliance, as standard domestic tax preparers lack the cross-border expertise required to navigate extraterritorial filings.
