Australia must obtain a visa prior to travel. The only exceptions to the rule are holders of New Zealand passports and citizenship, who may apply for a visa on arrival according to the Trans-Tasman Travel Arrangement. In 2020, in Love v Commonwealth, the High Court of Australia ruled that Aboriginal Australians (as defined in Mabo v Queensland (No 2)) cannot be considered aliens under the Constitution of Australia, regardless of whether they were born in Australia or hold Australian citizenship. Canada In Canada, the term "alien" is not used in federal statutes. Instead, the term "foreign national" serves as its equivalent and is found in legal documents. The Immigration and Refugee Protection Act defines "foreign national" as "a person who is not a Canadian citizen or a permanent resident, and includes a stateless person." United Kingdom In the United Kingdom, the British Nationality Act of 1981 defines an alien as a person who is not a British citizen, a citizen of Ireland, a Commonwealth citizen, or a British protected person. The Aliens Act of 1905, the British Nationality and Status of Aliens Act of 1914 and the Aliens Restriction (Amendment) Act of 1919 were all products of the turbulence in the early part of the 20th century. United States Under the Immigration and Nationality Act (INA) of the United States, "[t]he term 'alien' means any person not a citizen or national of the United States." People born in American Samoa or on Swains Island are statutorily "non-citizen nationals." Others, such as natives of Palau and the Marshall Islands, are legal immigrants and aliens for INA purposes. Every refugee that is admitted to the United States under automatically becomes an "immigrant" and then a "special immigrant" after receiving a green card. The usage of the term "alien" dates back to 1798, when it was used in the Alien and Sedition Acts. Although the INA provides no overarching explicit definition of the term "illegal alien", it is mentioned in a number of provisions under title 8 of the US code. Several provisions even mention the term "unauthorized alien". According to PolitiFact, the term "illegal alien" occurs in federal law, but does so scarcely. PolitiFact opines that, "where the term does appear, it's undefined or part of an introductory title or limited to apply to certain individuals convicted of felonies." Since the U.S. law says that a corporation is a person, the term