Vereinigte Staaten–Deutschland
Kapitalanlagen und Quellensteuern
Cross-border portfolios can create different tax results in the United States and Germany. Brokerage accounts, dividends, interest, capital gains, ETFs, mutual funds and withholding taxes must be classified under both systems.
Übersicht
The same investment can be treated differently in each country
Start with the investor's residence and U.S. status, then classify each account and investment under both tax systems.
For U.S. taxpayers, many non-U.S. funds can require PFIC analysis and Form 8621 reporting. For German residents holding U.S. investments, German taxation, U.S. withholding and treaty relief must be coordinated.
Das gleiche Thema aus deutscher Sicht betrachten
The German TaxRep page focuses on German taxation of U.S. investments and relief from U.S. withholding taxes.
Häufige Situationen
Start with the investor and the account
U.S. brokerage account after moving to Germany
German residence begins while the U.S. securities remain in the existing account.
Situation anzeigenU.S. taxpayer holding German ETFs or funds
Non-U.S. investment funds may trigger PFIC analysis and Form 8621 reporting.
Situation anzeigenGerman resident receiving U.S. dividends
U.S. withholding, treaty relief and German taxation have to be coordinated.
Situation anzeigenGerman resident earning U.S. interest
Source-country treatment and German taxation depend on the instrument and investor status.
Situation anzeigenSale of U.S. securities after moving to Germany
Cost basis, move timing and German capital-gain rules become important.
Situation anzeigenU.S. citizen with German bank and brokerage accounts
German taxation must be coordinated with U.S. income and foreign-account reporting.
Situation anzeigenSchlüsselfragen
What should be checked?
Are German ETFs PFICs?
Many non-U.S. investment funds can fall within the PFIC regime. Classification should be checked before investment.
Can I keep my U.S. brokerage account?
Broker location does not determine taxation. German residence can bring worldwide investment income into the German return.
How are U.S. dividends taxed?
German taxation, U.S. withholding and treaty relief must be coordinated.
Is there a German step-up on arrival?
A general automatic step-up for private securities should not be assumed; preserve historical acquisition data.
Which records matter?
Acquisition date, cost basis, lots, distributions, taxes withheld, sales and corporate actions.
Can foreign taxes be credited?
Creditability and recoverability are separate questions and must be coordinated with treaty rules.
Technische Anleitungen
Detailed investment guides
U.S. brokerage account after moving to Germany
German reporting, dividends, gains and recordkeeping.
Anleitung lesenGerman ETFs and mutual funds for U.S. taxpayers
PFIC classification, Form 8621 and fund selection.
Anleitung lesenU.S. dividends for German residents
Withholding tax, German tax and treaty coordination.
Anleitung lesenU.S. interest income for German residents
Source-country treatment and German taxation.
Anleitung lesenSelling U.S. securities while resident in Germany
Cost basis, move timing and capital gains.
Anleitung lesenGerman brokerage accounts, FBAR and FATCA
U.S. reporting for German financial accounts.
Anleitung lesenInvestment planning before moving to Germany
Portfolio review before German residence begins.
Anleitung lesenZweiseitige Führung
Weiter mit der Perspektive von TaxRep Deutschland
Kapitalanlagen & Quellensteuern
German tax perspective on U.S. investments.
taxrep.de öffnenWohnsitz & Umzug
Residence determines which investment rules apply.
Explore residencySteuererklärungen und Berichterstattung
FBAR, FATCA, Form 8621 and annual compliance.
Berichterstellung erkundenVereinigte Staaten–Deutschland
Return to the cross-border hub.
Zurück zu HubSteuerberatung für die USA und Deutschland
Holding investments across both countries?
We coordinate investment taxation, PFIC exposure, withholding taxes, foreign tax credits and reporting.
Discuss your investment situation