British nationals enjoy(ed) the right of free movement within the EU. They could live, work or retire in any one of the other 27 member-states and "enjoy equal treatment with nationals in access to employment, working conditions and all other social and tax advantages." They also benefited from specific EU agreements that covered healthcare and other social benefits. It was one hell of a deal. As an American (a "third-country national") I could only envy my British friends and be very grateful that my children are EU citizens.
Their fate is now in the hands of the government they left behind and the EU negotiators. A worst-case scenario would be where the British government makes all the EU citizens leave which might trigger a similar deportation of British citizens from the EU. That is a frightening prospect.
Almost as frightening is the prospect of having to apply for residency in the countries where they live. If they are no longer EU citizens then they are demoted to "third-country national" status which means that they get in line with everyone else at the immigration office. Getting a residency permit in places like France is not easy. There will be a cold hard eye cast on them by the government and the French public. Do they speak French? How integrated are they? Are they sick? Old? Do they use the French social welfare system? Do they work? Do they have skills? What exactly is their contribution to French society? I would hope that they would be treated kindly and allowances made for age and health and length of residency. Because among these British expatriates are a lot of retirees. Not rich folks, but people on budgets whose pensions went a lot farther in Spain than they did in the UK.
These "Brexpats" are organizing. In Spain there is an organization called Brexpats in Spain. In France there is RIFT (Remain in France Together). And there is a larger umbrella organization called British in Europe which brings together groups based in different EU member states. Recently, the British ambassador to France sent this message to the British in France clearly in the hope of calming people down (hat tip to Survive France for the link on Facebook). He assures them that their wellbeing is a "top priority."
Patrick Weil (a man whose opinions are always worth listening to) says that France should simply give the British in France the right to apply for French citizenship. I see his point and I like his argument but for me it probably doesn't pass the French mother-in-law test (my mother-in-law wouldn't like it and she votes.) In the comments section I already see the arguments against it: why should a British man or woman go to the head of the line when other immigrants from Africa or North and South America who have lived in France just as long have to wait.
It's impossible to know how this story will end. Brexit itself was never supposed to happen. As the British and EU negotiators prepare to
18 comments:
I would tend to be on the side of your mother-in-law however, there is a very technical argument that under Vienna Convention on Treaties and customary international law EU citizens residing in the UK up until Brexit day will be allowed to stay.
I think the real issue is in the hands of the UK. Do they allow EU citizens to stay? I don't know. I will say that Emmanuel Macron who is currently the leading French Presidential candidate is absolutely despised and hated in much of the British media especially those parts that strongly supported Brexit. Logically even as a matter of domestic UK politics it makes sense to allow EU citizens to stay in the UK however, in the event of a Macron victory I could see a visceral desire on the part of some Brits to be seen as attacking Macron, France, and the EU. For example Nigel Farage has already come out and said he loaths Macron.
Many Europeans in the UK are feeling the push to leave, get residency or apply for citizenship.
As an American retired to Ireland on the strength of my husband's EU/UK citizenship, the sharp end of Brexit is gut-churning.
I've been told by well-meaning friends and neighbours not to worry: that the pre-EU Common Travel Agreement between Ireland and the UK, giving citizens of each State the right to live and work in the other, could well come back into effect (if the EU allows it). That's a sweet thought, but the CTA never covered third-country spouses or family members. If, under a revived CTA, I'm tested against Ireland's eye-watering financial requirements for non EU/EEA citizens to gain residency (an annual guaranteed income of €50,000 per person), I will fail. My husband could stay, but I'd be out.
My lifeline has been the discussion about offering UK citizens a form of associate membership in the EU--if my husband (an ardent Remainer, I might add) could still hold free movement rights, he could stay and I could conceivably gain permanent residency as an EU-citizen spouse. But it's another huge if.
So the ripples from Brexit spread, and having our future depend on the British government is probably the most frightening thing that I've experienced in my admittedly sheltered and privileged life; I trust the EU rather more than Mrs. May. Previously I'd found it nearly impossible that anyone would think that the forced migration of around 4.2 million EU and UK citizens was a good thing...but sometimes now I'm starting to doubt.
Pour ma part, Looking forward to Trumpxit!
Bon je lisais ta presentation, cancer survivor, veux pas donner de conseils, mais sur ta photo, cigarette, bon c est un joint peut etre....
Do you think that if other nations of the world and its citizens really knew the full impact of the US' taxation based on citizenship, the rest of the world would be as willing as is to embrace US emigrants on any level?
Although I don't see other nations making any policy decisions to exclude Americans, I do know that Americans are making their own 'USxit' so to speak by renouncing their US citizenships in record numbers.
The fall-out from Brexit and the Trump executive orders on immigration have brought home to me the difference between citizenship and any lesser status of residence. The UK citizens in the EU and EU citizens in the UK have essentially had their permanent residence permissions revoked. The first Trump order prevented even US Green Card holders from re-entering the US, if they happened to have been born in the wrong country.
A sobering trend, if it is one.
Tim: I think that argument has been bought up concerning their residency. Citizenship is something else. What is really worrisome for the retirees is that the reciprocal agreements on healthcare may no longer apply. Under the EU agreements EU member shates were reimbursed by the UK for the health costs of British retirees.
Ellen, That doesn't surprise me. Some really nasty rhetoric in the UK. Did you see that the helathcare industry in the UK wants to make an exception for foreign healthcare workers. It appears that European doctors and other care workers are leaving and that has the government worried.
Donna, Thank you very VERY much for your comment. Yes, that is another facet of Brexit - spouses of EU citizens in the UK. I am so sorry - you must be very stressed and rightfully so. Do you have a voice? Is there any association working on behalf of the families of EU citizens living in the UK? And, if I may ask, do your British friends and neighbors understand how Brexit has impacted you?
Therese, Bonjour! Eh oui. J'ai arrete pendant presque un an. Helas, j'ai repris la cigarette recemment a cause de mes etudes. Maintenant, il me faut le courage d'arreter encore une fois. Pas facile. Mais je vais le faire.
Bubblebustin, So good to see you! How are you? Excellent point. I have been doing my part here to spread th news. Unfortunatley, very few Americans I've met here even know what FATCA is or that citizenship-based taxation exists and they aren't too happy when I brint it us.
Donna, I reread your comment and I see that I misunderstood your situation entirely. You are in Ireland, not the UK. So let me reformulate my question: Are the Irish aware of your situation and what is their reaction? Are there any associations in Ireland that could help?
Nezumi-san, Absolutely. There is more vulnerability if you are just a permanent resident. That said, in Japan there is Spcial Permanent Resident status. How close is that to citizenship? Do they have the right to leave Japan and return?
I'm not an expert on the subject, but as far as I know, while Special Permanent Residents get some slightly better terms than regular Permanent Residents, legally SPR is still not the same as citizenship. SPRs cannot vote, for example. (Well, I think there may be some local elections they can vote in, depending on the municipality, but nothing at the national level.)
I think SPRs are able to stay out of the country longer than regular PRs before losing their residency status, and they have somewhat simplified requirements for naturalization. But overall I'd say SPR is closer to regular PR than it is to citizenship. And of course, SPR is not a status one can apply for -- one was born that way or not.
Correction: If one is old enough, one would have become an SPR by decree, rather than at birth.
Victoria, I will wager that your mother-in-law, like 99% of her native-born compatriots, has no particular knowledge of French nationality law or the rules and procedures for naturalization (it's likewise for Americans; I have been repeatedly struck, in the course of my life, by the ignorance of even highly educated Americans on matters having to do with citizenship and nationality).
On the Brexit vote and immigration, there's a good article in the December 2016 issue of Population and Development Review, "Why Brexit? The Toxic Mix of Immigration and Austerity," by Stuart Gietel-Basten, of the Department of Social Policy at Oxford University (you should be able to find it via your university library's online data base). Among other things, he details the demagoguery and abject lies of the Leave campaign on the immigration issue, and which were relayed almost daily by the right-wing tabloid press (Britain's answer to Fox News, Breitbart et al) — and which were decisive in the Leave's victory.
The article confirmed two thoughts I've had for a while, one being that anti-immigration sentiment in public opinion does not emerge spontaneously. It is systematically stoked up by demagogic, vote-seeking politicians, who play on peoples' fears and prejudices, via gross distortions and outright lies. The other is that the vast majority of voters have little to no understanding of the dynamics of migration and immigration (and there's no reason they should; what we know about any complex issue is the fruit of extensive reading and taking an active interest in it). As for politicians, some understand the issue but more do not, particularly those on the restrictionist side. E.g. you may have seen the New York Times op-ed last December by Senator Tom Cotton (R-AR), who's a leading immigration restrictionist in Congress, on how to "fix" immigration. As a Harvard graduate one would think he would have done his homework on the issue but this was not in evidence in the ill-informed op-ed. And he offered no precise policy prescriptions.
On Patrick Weil's proposal, as UK citizens are still European citizens, they do, juridically speaking, enjoy a privileged position in France over those from non-EU countries.
Victoria, as far as I know, there are no organisations as such that would help with this issue; I suppose because nothing yet is certain. We could contact our local representatives in the Dáil and Seanad for their help but, since the US doesn't intend to give any leeway to the 50,000 undocumented Irish immigrants currently in the US (this according to Sean Spicer), I couldn't blame our Irish representatives if they were disinclined to do much on our behalf.
The Irish people in general are focused, quite rightly, on the border with Northern Ireland and the economic impact, which stands to hit Ireland the hardest of all the EU countries. The CTA has been around for so long--since 1925 in one form or another--that it's taken for granted that there will always be a place for UK citizens in Ireland, and if I point out the complications of our circumstances the response I hear every time is that "surely something will be worked out." I'd be naive to agree.
At least if the immigration issues are decided by the end of this year, as was reported last week, we'll have time to act on contingency plans.
Arun, Thank you for the article. I will read it today. My mother-in-law is a wonderful woman but, yes, she gets all of her information from the media. Since she comes from a rural area she retains a keen interest in that state of rural regions in France. Her impressions of the British in France is that they are taking over rural villages and buying homes that used to belong to French families. Facts are not useful here and only serve to turn a nice Sunday dinner into a battlefield. Does the media and politicians play on the fears of people like her in France and in the UK? Absolutely. I think that changing people's minds about such things needs more stories and fewer facts (which is also manipulation but hey....) Tell the story of a British retiree who has been in France for 10 years and how much he loves France and his house. Show him speaking French to his neighbors. Give her real people with whome she can indentify and empathize. It's not the solution but it helps.
Donna, Thank you your reply. I had not considered the issue of the Irish in the US and how that might have an impact on your situation. Much to think about here. Crossing my fingers here and hoping that sanity and humanity will prevail.
Meeting real people does indeed help break down barriers. There was an interesting article in this vein in Foreign Policy last month: "Welcome to Wimberg: Population 1,800 (+300 Refugees): Two years after the height of the migration crisis, Germany is learning that newcomers fare best in tiny villages, not big cities." https://foreignpolicy.com/2017/03/22/welcome-to-wimberg-population-1800-300-refugees/
In my small French village, which normally is very friendly, twice I was told to get out and that they didn't like Brits in days after the Brexit vote. I told them I was Swiss. One said that was as bad. My accent is definitely Anglo American but not necessarily identified.
Xenophobia can be international.
I don't mind being disliked for what I do, but reject the idea I am rejected because of a red or blue passport.
Brexit has given me an unexpected kick.
I'm Irish, living and working a long time in Belgium. When Theresa Mayhem signed the Article 50 letter last week to start to departure process, a couple of Belgian colleagues joked with me about our (Ireland's) departure from the EU. They had the impression that Brexit includes the Republic of Ireland too! My colleagues saw us as being in some way part of the UK (talk about nearly choking!) One of them was amused to think how we'd cope once Britain left since trucks wouldn't be able to drive through Britain anymore to Ireland. He was amazed to hear that there are ferries between France and Ireland. A French colleague yesterday at lunch also commented about Ireland's departure from the EU as part of Brexit. There is confusion about what Brexit means but also in some minds what exactly is the "United Kingdom". I hope I don't many more such kicks over the next 2+ years.
Arun, I think it does help. I read the article you directed me to and, yes, a beautiful example of framing - connect the "foreigner" to the healthcare budget deficit. Sneaky and false but effective.
Donna: Yikes. I'm hearing vague echoes of that where I am. "Well, the Brits were also a problem and they have lousy food and bad manners. Kick them out." Nice. And the next time the US government does something really stupid are you going to tell me to leave too?
Unknown, Well, that's a surprise. Sounds like they need a lesson in geopolitics. Myabe this map would help: http://brilliantmaps.com/eng-gb-uk/
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