Germany–U.S. Moving Scenario
German Moving to the United States
A move from Germany to the United States can end or reduce German residence taxation while beginning U.S. federal tax residency. The transition year should coordinate departure from Germany, U.S. residency-start rules, worldwide income, investments and both countries' filing obligations.
Übersicht
The move can shift the residence-country tax system
Before the move, Germany may tax the individual as a resident. After U.S. tax residency begins, the United States can become the primary residence-country system for worldwide income.
The difficult part is the transition: determining the relevant dates, identifying any period of overlapping residence and ensuring that the German departure-year return and the first U.S. resident return use consistent facts and income data.
German tax perspective
The German TaxRep counterpart focuses on ending German residence, remaining German-source income and the German departure-year return.
U.S. Tax Residency
Tax residency can begin through a Green Card or physical presence
Green Card Test
A lawful permanent resident generally becomes a U.S. resident alien for federal tax purposes under the Green Card Test. The starting date depends on the facts and the applicable residency-start rules.
Substantial Presence Test
A person without a Green Card can become a U.S. tax resident based on physical presence under the statutory day-counting test.
Dual-status year
The first U.S. year can involve both nonresident and resident periods. Filing format and income inclusion depend on the residency starting date.
Leaving Germany
German tax residence does not end merely because a flight departs
Deutsche Wohnung
A dwelling that remains available for personal use can continue to create German domestic residence even after relocation to the United States.
Center of life
Family location, available homes and actual living arrangements can matter when residence overlaps and treaty residence must be evaluated.
German-source income after departure
German real estate, business interests or other German-source income can remain taxable in Germany even after unlimited German taxation ends.
Departure-year return
The German return should reflect the correct residence period and any continuing limited German tax liability after departure.
Pre-Move Investment Review
German funds and financial accounts should be reviewed before U.S. residency begins
German and European funds
Non-U.S. mutual funds and ETFs can become PFICs once the individual is subject to U.S. taxation as a resident.
Form 8621 and German fundsGerman bank and brokerage accounts
German financial accounts may later become relevant for FBAR and Form 8938 reporting after U.S. tax residency begins.
Steuererklärungen und BerichterstattungGerman GmbH or partnership interests
Foreign-company and partnership ownership can create U.S. information reporting after the move.
Unternehmen und BeteiligungenGerman pensions and retirement assets
German pension arrangements should be documented before U.S. residence begins because U.S. treatment may differ from German treatment.
Renten & RuhestandMoving-Year Filing
The German departure return and first U.S. return should be coordinated
Residence timeline
Document German departure, U.S. arrival, available homes, Green Card dates and physical-presence days.
Income by period
Separate employment, investment, business and other income according to the relevant residence and source periods.
U.S. filing status
The first U.S. year may be a resident, nonresident or dual-status filing year depending on the applicable tests and starting date.
German tax paid
German taxes associated with income also subject to U.S. tax may need to be coordinated with U.S. foreign tax credit rules.
Meldung ausländischer Konten
Track German bank, brokerage and financial accounts for possible FBAR and FATCA reporting once U.S. rules apply.
State tax
State residence and filing obligations should be analyzed separately from U.S. federal tax residency.
Related U.S.–Germany Guides
Continue with the issues surrounding the move
Wohnsitz & Umzug
Residence, treaty residence and moving-year questions.
Explore residencyMoving-Year Tax Return
Coordinating income, residence periods and both countries' returns.
Explore moving-year filingSteuererklärungen und Berichterstattung
U.S. tax returns, FBAR, FATCA and foreign-entity reporting.
Berichterstellung erkundenVereinigte Staaten–Deutschland
Return to the complete cross-border tax hub.
Zurück zu HubGermany–U.S. Move Planning
Moving from Germany to the United States?
We can coordinate German departure taxation, U.S. residency-start rules, the moving-year tax returns, investments, foreign accounts and ongoing U.S.–Germany reporting.
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