of resident Koreans who had not acquired permanent residence status. “The special law concerning immigration control with respect to those whose Japanese nationality was renounced based on the Peace Treaty with Japan” effectuated on January 1, 1991 (Immigration Bureau Special Law) established Law 126, which combines Permanent Residence Status (of the 1965 Agreement) and Special Permanent Residence together to create a “Special Permanent Resident Status,” which was aimed to further improve their legal status in terms of deportation and reentry. The legal status of resident Koreans with special permanent resident status has become closer to that of Japanese citizens when compared to other foreign nationals. However, they remain foreigners in Japan,153 with the exception of those who have been naturalized.154 The treatment of the nationality of Koreans residing in Japan has not always been clear. The 1963 Nationality Act of DPRK (North Korea) and the 1948 Nationality Act of RK (South Korea) both regard all Korean residents in Japan, excluding those who have been naturalized, as their respective citizens. In an effort to avoid a political tangle between the two Koreas, the Japanese government initially listed “Chosen (the area name covering the Korean Peninsula and its surrounding islands)” on the alien registration card for Koreans. When the individual so requested, this was later changed to “Kankoku (the abbreviated name for the Republic of Korea)”. After the 1965 Treaty on Basic Relations with the Republic of Korea, “Kankoku” was formally a nationality, but “Chosen” was a mere symbol. The Japanese government has not recognized the DPRK and its nationality law up to now, so it has applied the Republic of Korea’s nationality law for nationality problems of resident Koreans. The General Association of Korean Residents issues passports under authorization by the North Korean Foreign Ministry, but these have not been approved as valid by the Japanese Government. When residents in Japan travel abroad with this passport, the Japanese government issues them a reentry permit. In administrative practice, a “foreign country” in the Nationality Law refers to countries that Japan has recognized, so a Japanese national cannot renounce Japanese nationality to acquire the nationality of the DPRK. However, since the DPRK clearly satisfies requirements of a State under 153 It should be noted that there are more than a few Koreans who, unable to meet the requirements of special permanent resident status for a variety of reasons, continue to reside as general permanent residents. 154 The number of those acquiring Japanese nationality by naturalization has been increasing. See supra note107. 56

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