92 Unwanted and ambivalent citizenship with sole allegiance or is not a citizen at all then these developments make sense. And yet individuals’ lives are more complex than this. This will become particu larly clear below, in the discussion of nomadism. However, first let us examine some core areas of contention that have been raised in the context of plural cit izenship. Major arguments against plural citizenship include the question of how and whether a person could satisfy or fulfil her/is duties with regard to each of the States with which s/he holds citizenship.46 This is particularly clear in the cases of military service and voting, and so I will pick up on these here. It is important to note that historically, the belief that a person has another allegiance beyond a particular formal citizenship is not dependent only upon that person being a formal citizen of another State. This is particularly tragically clear in the case of those US citizens of Japanese descent who did not need to be formal Japanese citizens in order to be assumed to have some allegiance with Japan and so to be interned. Their ethnic heritage was considered sufficient to generate a fear that they would side with Japan against the US in the Second World War. The apparently crisp legalistic notion of plural citizenship, then, was (as in the cases of other citizen noncitizens above) conflated with ethnic identifi cations of membership. As a result, Ben Herzog notes that ‘5,589 American citizens of Japanese descent were forced to renounce their citizenship.’47 This is related to Henio Hoyo’s naturalised citizens in the South American countries discussed above, where full citizenship was not only about legal and formal citizenship, but also about birth and blood. Distrust of plural citizenship, then, is not only about concerns relating to the shared allegiance of formal citizens. It is also tied up with assumptions about birth, blood, ethnicity and race. As such, as Shachar has also pointed out, birth right citizenship, however it is construed (whether by birth to citizen parents or by birth upon a particular territory) can also be a proxy for other distinctions that are difficult to align with liberal democratic principles. The analytic tool of ‘non citizenship’ can help us to interrogate this. Let us consider what this means for voting. The loyalties of plural citizens came under the spotlight in Australia in 2000 when there was concern about Italian citizens living in Australia voting in Italian elections. Italy had introduced new rules allowing postal votes and creating expatriate constituencies in the Italian parliament (these persons may or may not have also held Australian citizenship).48 The public debate in Australia at the time uncovered a wider issue 46 For example, see Tanja Brondsted Sejersen (2008) ‘ “I Vow to Thee My Countries” – The Expan sion of Dual Citizenship in the 21st Century’, pp. 523–549 in International Migration Review 42(3) at p. 526. 47 Ben Herzog (2015) Revoking Citizenship: Expatriation in America from the Colonial Era to the War on Terror, New York University Press, p. 95. 48 In 2001, the Italian Parliament created four overseas constituencies: Europe; South America, North and Central America; Africa, Asia and Oceania; and Antarctica. Arguably, the overseas electorate was key in electing Berlusconi in the 2006 election, in which 1 million expatriate Italians voted (Dauvergne 2008, p. 133). Catherine Dauvergne (2007) ‘Citizenship with a Vengeance’, pp. 489–508 in Theoretical Inquiries in Law 2(6).