What bugs me is that in THE form for citizenship ("Form CIT 0002") you have two fields for your address in which it is written:
1. "home address (residence in Canada)"
2. "mailing address"
So, it is like you can't actually use your address abroad and you have nothing to put it if you don't rent or own (millenials can't afford to own anything anyway) propriety in Canada.
Yeah. That's right. Citizenship applicants are required, in item 7 (in CIT 0002 (06-2019), the current version), to provide the address where the applicant actually lives.
And of course it makes total sense that IRCC wants this information. It is a key piece in the whole picture of who the applicant is and the life the applicant is living, which is an important factor to be considered in weighing the veracity of key information directly relevant to the qualifications for citizenship, not the least of which is the applicant's identity and physical presence history, but also for purposes of background screening for criminality or security prohibitions.
Even if the applicant owns or rents a dwelling in Canada the citizenship applicant is required to provide the address
where the applicant actually lives . . . NOT the applicant's "domicile." Not an address the applicant believes he or she can use as a residential address. BUT, rather, the address where the applicant is actually residing. To do otherwise is misrepresentation. That is, FRAUD. Common, yes. But a rather steep downside for those who, so to say, do not get away with it.
I do not know what happens if the applicant populates item 7 with a foreign address. A number of forum participants have reported successfully applying for citizenship while living abroad, so it appears IRCC will proceed with processing despite giving a foreign address as place of current residence. (Of course this assumes those applicants provided truthful information about their actual residential address, and thus did not commit fraud.)
I do know that if the applicant is in fact living outside Canada and the applicant uses a Canadian address as his or her home address that is misrepresentation.
I know how to approach this without committing fraud and in a way that IRCC will process the application despite providing a foreign address. But since IRCC apparently expects applicants to actually be residing in Canada when they apply (even though there is no statute or regulation requiring this . . . similar to applications for new PR cards), and to my view applying from IN Canada is so much more prudent, to me it is not worth wandering down that side street.
Is this inconvenient, perhaps problematic, for PRs living abroad and wanting to apply for citizenship? No doubt. Unreasonably so? Since there is a work-around (again, to my view that's a side street worth passing by) and even if IRCC insists an application is NOT complete without a home address in Canada (and thus will not process it; but since a number of forum participants have reported successfully applying for citizenship while living abroad, it appears IRCC will proceed with processing despite a foreign address, again assuming of course those applicants did not commit fraud), an applicant can request (virtually a demand) the application be processed anyway, it is NOT likely a Federal Court will find the current application requirements to be unreasonable.
SOME FURTHER LARGELY TECHNICAL OBSERVATIONS
While the IRCC instructions are more direct for PR card applications, specifically stating that the application must be made IN Canada, the implication for grant citizenship applications is similar to applying for a new PR card in that IRCC expects applicants to be residents of Canada, living in Canada.
There is no statute or regulation requiring actual residence in Canada, at the time of the application or while the application is pending, to be eligible. For either application. For either a new PR card or grant citizenship. So there is no overt enforcement of the instructions (explicit in PR card applications; implicit in citizenship applications). EXCEPT, of course, there is the substantially elevated risk (perhaps even likelihood) of non-routine processing, which typically includes increased scrutiny and longer processing times.
While some may quibble with the policy, it is what it is. How things should work is outside my bailiwick. For me it is difficult enough figuring out and keeping up with how things actually work, at least as best we can given a lack of transparency (dramatically expanded during the Harper government and not rolled back that much since).
Which leads back to this observation: "
So, it is like you can't actually use your address abroad and you have nothing to put it if you don't rent or own (millenials can't afford to own anything anyway) propriety in Canada."
Let's be clear:
-- Place of residence is the address where an individual is
actually residing, the individual's place of abode
-- "Domicile" and current place of residence are NOT necessarily the same (complicated subject, but for sure, a person's current residential address can be different from his or her domicile).
-- The grant citizenship application does NOT ask for the applicant's "domicile."
-- The grant citizenship application does ask the applicant to provide
place of residence address, including
-- -- Current residence address
-- -- Residence address history for previous five years
Let's also be clear: the applicant is required to provide this information under penalty, including penalties prescribed under the Citizenship Act itself, and potential CRIMINAL penalties.
And, ultimately, while a few may be irked by the way IRCC structures its application forms and instructions, it is hardly any surprise that IRCC makes it inconvenient to apply for either a new PR card or citizenship while living abroad.
As I have oft discussed in this forum, many PRs fudge their information in regards to providing addresses (including the outright fraudulent listing of a home or dwelling owned or leased in Canada as their residential address when in fact that is NOT where they reside), and many appear to get away with this. That it worked does NOT mean it is OK, does not mean that it is not misrepresentation, and does not mean that it is not potentially subject to severe penalties (possibly even a sojourn in secured public housing, the kind with few or no windows). The fact that it may be easy to get away with it is NOT a green light. And, it warrants cautioning, it is quite likely many do NOT get away with it.
