screech339 said:
I would think the US government would rather fine / convict US citizen over removing citizenship. They need their income tax money. So it is very unlikely that US would arbitrarily revoke US citizenship.
Most dual Canadian/U.S. citizens do not owe taxes to the IRS. The sort who are likely to owe the IRS taxes are also the sort who are likely to have attorneys to fight their case in the USA, and are thus less likely to be targets of the Department of State (DoS). Further, the cost of processing expatriate returns is far greater (by magnitudes) than the taxes produced by such returns. The DoS, as a general rule, does not concern itself with issues of taxation.
If a U.S. citizen commits a potentially expatriating act, like being "naturalized" as a Canadian citizen,
with the intent to relinquish U.S. citizenship, then that citizen may cease to be a citizen from the date of the expatriating act. How does the DoS determine if there was intent to relinquish? It looks at behaviour, to wit, did the citizen behave, in word or deed, in a way an American would behave? For example, applying for a U.S. passport right after naturalizing as a Canadian would clearly establish that the citizen's intent was to remain a U.S. citizen. On the other hand, applying for a visa to enter the U.S. on a Canadian passport would just as clearly establish that the citizen's intent was to relinquish U.S. citizenship upon naturalizing as a Canadian (the rationale being that a U.S. citizen would never apply for a visa to enter America).
The U.S. Government has revoked citizenship from dual Canadian/U.S. citizens in the past. They have often done this without notifying the citizen, on the presumption that citizenship was relinquished upon the commission of a [potentially] expatriating act. The U.S. Government has also retroactively reinstated citizenship, again, without notice, which has resulted in at least a few citizens incurring thousands of dollars in tax penalties for failing to file tax forms (though no taxes were actually due). These cases almost never make it to court because the financial burden of seeking redress is too great. Homelanders (Americans living in America) have zero sympathy for expatriates and dual citizens -- they're viewed as "Unamerican" and their "patriotism" is suspect -- so turning to the media to publicize this injustice is likely to backfire and result in the public and politicians ardently supporting doubling-down on the injustice.
As a matter of policy, the current, and recent, presidential administrations have taken a lax view on dual citizenship and have only given lip-service to discouraging it. The courts, while allowing dual citizenship, give the DoS significant leeway in how they choose to "discourage" dual citizenship. Earlier administrations were far more stringent in applying policy and discouraging dual citizenship. The Department of State does not always act in ways that seem, at least on the surface, legal and constitutional. The courts can correct any oversteps -- but seeking redress in the courts may cost upwards of US$ 250,000 and take as long as 18 years to reach a mandate at the Circuit Court of Appeals. (The challenge of finding competent attorneys -- note that's plural, not singular -- while possibly being banned entry into the U.S., is daunting.)
Elections have consequences! DoS policy is determined by the president. The DoS has no statute of limitations on [potentially] expatriating acts and indica of intent when adjudicating relinquishments of citizenship.