Getting Greek Citizenship? What are the United States Consequences?

James (Dimitrios) Pappas (not a real person!) decides to get Greek citizenship. He was born in the U.S. (Chicago, say) of Greek ancestry and wants that famous "dual citizenship". Part of the Greek citizenship process is registering a Greek οικογενειακή μερίδα (family share), getting a Greek passport etc...

This, in essence, means acquisition of Greek "nationality". Well, James resides in the U.S. but has real estate in the U.S. and Greece. He has three children but his U.S. Will provides that his Greek assets go only to two of them, a son and a daughter. The third son (Takis) is ungrateful and spends all his money on drugs and gambling. Also, James mistrust Takis' wife and fears that in any divorce she will take the third son's assets.

James dies and his U.S. Will excludes Takis completely. Unfortunately, Takis' wife knows some conniving Greek lawyers who tell her and Takis that, if James was a Greek national (dual-citizen), then the Greek Courts will choose the Greek nationality as primary. Thus, Greek law will apply as to the Greek assets. That being the case, Takis can asserts his nomimi mira (forced share) to block recognition and full enforcement of the U.S. Will in Greece. Now the other siblings (true and intended heirs of James) will suffer long and difficult litigation in Greece which can tie up the real estate for up to a decade! (Of course, there are ways to plan for this in advance - i.e. joint ownership/life gifts etc... - but that will be the subject of a later blog).