When incoming US president Donald Trump moved to revoke birthright citizenship, stripping people born in the country of their US nationality if their parents are non-citizen immigrants, some saw echoes of Nazi Germany.

However Germany, a nation formed in 1871 from diverse independent states, never gave automatic citizenship to those born in the country. Citizenship was ruled by the right of blood, based on the idea that German nationality was inherited, meaning one or two parents had to be German.

Yet citizen rights did not depend on race and religion. Some 400,000 Jews in the country, or 80% of the population, held German citizenship when Hitler became Chancellor in 1933. And foreigners were able to become citizens after remaining for 15 years in Germany.  

But this changed soon after the Nazis came to power. The Nuremberg Race Laws of 1935 revoked the the citizenship and basic rights of German Jewish people. The statute was soon expanded to make Roma and Black people stateless.

But is Trump's attempt to strip citizenship from US Americans whose parents were temporary or undocumented residents really comparable?

Birthright citizenship less common among industrialized nations

Birthright citizenship was enshrined in the US constitution in 1868 by Republicans who, after the civil war, wanted to give citizen rights to formerly enslaved African-Americans. The resulting 14th Amendment has become a defining symbol of a tolerant, multi-racial society — explaining why US states have successfully sued to block Trump's executive order that seeks to revoke the law.

"We are the only country in the world that does this with the birthright, as you know, and it's just absolutely ridiculous," said Trump when signing the order.

The fact-checking website Politifact said the president's claim was false. It noted that numerous countries in the Americas from Brazil to Argentina enshrined birthright citizenship; partly since they are former colonies that wanted to attract new citizens with lenient naturalization laws.

According to World Population Review, 35 countries in the world automatically give citizenship to people born there, irrespective of their parents' residency status. Germany's birthright citizenship, for example, is restricted. Canada and the US are the two only countries with unrestricted birthright citizenship that are also in the top 20 economies. 

Lawmaker calls Trump move authoritarian

"Citizenship stripping is, of course, a hallmark of authoritarianism," said Jamie Raskin, a US congressman from the Democratic party, during a committee debate on the 14th Amendment in February.

He referred to the "Reich Citizenship Law," a subsection of the Nuremberg Laws that revoked both citizenship and civil rights for German Jews in 1935 — a move soon introduced in other fascist states like Italy under Mussolini's rule.

"To this day, authoritarian countries deprive people of citizenship to punish them for political activism or dissent," the lawmaker added.  

Preserving the sanctity of citizenship by birth was something that made the US unique, he said.

"Privileges of citizenship are shared by all people born in our country, not just people who fall within a certain hereditary classification by race or national origin."    

In recent years, Germany has updated its naturalization laws to make it easier for people born in the country to non-citizen parents to become German citizens.

But now that Germany's new conservative government wants to tighten immigration rules — with the controversial support of the far-right AfD party — Chancellor Friedrich Merz also wants to reintroduce citizenship restrictions. 

Meanwhile, the US Supreme Court decided in June that the temporary injunction prohibiting the administration from scrapping birthright citizenship was unlawful. That said, the court is yet to rule on the merits of Trump's attempt to revoke a core tenant of the constitution.

Edited by: Elizabeth Grenier