U.S.–Germany Real Estate Scenario
Keeping a U.S. Home After Moving to Germany
Keeping a house or condominium in the United States after becoming resident in Germany can affect both countries. The tax result depends on whether the property remains available for personal use, is rented, produces a loss, or is later sold.
Vue d'ensemble
The property stays in the U.S. — but your residence changes
After moving to Germany, the United States remains the situs country of the property while Germany may tax you as a resident on worldwide income.
The property should therefore be reviewed from both sides: U.S. federal and state taxation of the property itself, and German residence-country taxation of rental income or a later disposition.
German tax perspective
The German TaxRep real-estate content focuses on German residence- country taxation of foreign rental property, foreign real-estate income and treaty coordination.
Property Use
Personal use and rental use lead to different tax consequences
Kept as a second home
A home retained for personal use may still be relevant to the overall residence analysis, especially around the year of departure, even though ownership alone does not determine treaty residence.
Converted to a rental
Once rented, gross rent, operating expenses, depreciation and financing costs must be coordinated under both U.S. and German tax rules.
Mixed personal and rental use
Periods of personal use and rental use should be documented because expense allocation and tax treatment can change with the use of the property.
Ongoing Taxation
Rental income may appear in both tax systems
U.S. federal and state tax
Rental income from U.S. real estate remains relevant in the United States. State-level filing may also continue depending on where the property is located.
Déclaration d'impôt sur le revenu en Allemagne
A German resident may also have to disclose the U.S. rental property and its income in Germany, subject to the applicable treaty treatment.
Depreciation differences
U.S. depreciation calculations should not automatically be copied into the German return. Basis, useful life and deductible amounts may differ.
Expenses and financing
Interest, taxes, repairs, management costs and other expenses should be classified separately under each country's rules.
Later Sale
A sale after moving to Germany requires advance review
Federal gain calculation
Original basis, capital improvements, depreciation and selling costs affect the U.S. gain calculation.
U.S. property salePrior principal-residence use
Prior use as a principal residence can be relevant to the U.S. sale analysis and should be documented before the property is converted to rental use.
Sale of former U.S. homeGerman treatment of the sale
German domestic rules and treaty allocation should be reviewed independently from the U.S. calculation.
German tax on U.S. property saleDouble-tax relief
If both systems impose tax on the transaction, the treaty and foreign-tax-credit mechanics need to be coordinated.
Crédits d'impôts étrangersPlanning & Documentation
Keep the records before they become difficult to reconstruct
Original purchase documents
Retain closing statements, purchase price allocation and acquisition-cost records.
Capital improvements
Keep invoices and records for improvements that may increase basis for a later sale.
Rental conversion date
Document when personal use ends and rental activity begins, including the property's condition and value at that time.
Annual income and expenses
Maintain a complete rental ledger rather than relying only on U.S. tax-return figures for the German filing.
Currency conversion
German reporting requires euro-based amounts, so transaction dates and original U.S. dollar figures should remain available.
Sale timing
Review a planned disposition before signing, particularly if the property was formerly a principal residence or has accumulated depreciation.
Related U.S.–Germany Guides
Continue with the issues connected to the property
Immobilier
U.S. and German property ownership, rental income and sales.
Explore real estateRésidence et déménagement
Residence and moving-year issues when a U.S. home is retained.
Explore residencyDéclarations fiscales et rapports
Coordinated U.S. and German annual filings.
Explorer les rapportsÉtats-Unis-Allemagne
Return to the complete cross-border tax hub.
Retour au hubU.S.–Germany Real Estate Tax
Keeping U.S. property after moving to Germany?
We can coordinate the U.S. and German tax treatment of personal use, rental income, depreciation, expenses, foreign tax credits and a later sale.
Discuss your U.S. property