490 Melbourne University Law Review [Vol 40:456 French proposal193 and the intended repeal of the Canadian provisions194 ---indicate that ‘[t]he trend is not linear’.195 The Allegiance to Australia Act introduced three new grounds on which a dual (or multiple) national may lose his or her citizenship.196 First, a person aged 14 or above is deemed automatically to renounce his or her Australian citizenship ‘(including a person who became an Australian citizen [at] birth)’,197 if he or she ‘acts inconsistently with their allegiance to Australia by engaging in’198 terrorist activities, which include ‘providing or receiving training connected with preparation for, engagement in, or assistance in a terrorist act’,199 ‘financing terrorism’,200 and ‘financing a terrorist’.201 Such acts must have been carried out ‘with the intention of advancing a political, religious or ideological cause’ and of ‘coercing, or influencing by intimidation’ the government of any country, state or territory or ‘intimidating the public or a section of the public.’202 The Act provides that: (4) A person is taken to have engaged in conduct with [such] intention … if, when the person engaged in the conduct, the person was: (a) a member of a declared terrorist organisation … or (b) acting on instruction of, or in cooperation with, a declared terrorist organisation. … 193 Kim Willsher, ‘Hollande Drops Plan to Revoke Citizenship of Dual-National Terrorists’, The Guardian (online), 30 March 2016 <http://www.theguardian.com/world/2016/mar/30/ francois-hollande-drops-plan-to-revoke-citizenship-of-dual-national-terrorists>. 194 Jocelyn Kane, Change Is in the Air: Statelessness and Citizenship in Canada (7 April 2016) European Network on Statelessness <http://www.statelessness.eu/blog/change-airstatelessness-and-citizenship-canada>: The Government of Canada has moved to repeal specific aspects of the recent legislation with Bill C-6, An Act to amend the Citizenship Act and to make consequential amendments to another Act. Among other proposed changes to immigration entry and residency requirements, the government has moved to repeal the measures by which Canadian citizenship can be revoked, thereby removing tiered citizenship and the possibility of creating a new cohort of stateless persons in Canada. 195 Foster and Lambert, above n 187, 581. 196 Allegiance to Australia Act sch 1 items 3--5. 197 Citizenship Act s 33AA(8). 198 Ibid s 33AA(1). 199 Ibid s 33AA(2)(c). 200 Ibid s 33AA(2)(f). 201 Ibid s 33AA(2)(g). 202 Ibid s 33AA(3).

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