États-Unis-Allemagne
Placements et retenues à la source
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.
Vue d'ensemble
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.
Aborder ce même sujet du point de vue allemand
The German TaxRep page focuses on German taxation of U.S. investments and relief from U.S. withholding taxes.
Situations courantes
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.
Voir la situationU.S. taxpayer holding German ETFs or funds
Non-U.S. investment funds may trigger PFIC analysis and Form 8621 reporting.
Voir la situationGerman resident receiving U.S. dividends
U.S. withholding, treaty relief and German taxation have to be coordinated.
Voir la situationGerman resident earning U.S. interest
Source-country treatment and German taxation depend on the instrument and investor status.
Voir la situationSale of U.S. securities after moving to Germany
Cost basis, move timing and German capital-gain rules become important.
Voir la situationU.S. citizen with German bank and brokerage accounts
German taxation must be coordinated with U.S. income and foreign-account reporting.
Voir la situationQuestions clés
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.
Guides techniques
Detailed investment guides
U.S. brokerage account after moving to Germany
German reporting, dividends, gains and recordkeeping.
Lire le guideGerman ETFs and mutual funds for U.S. taxpayers
PFIC classification, Form 8621 and fund selection.
Lire le guideU.S. dividends for German residents
Withholding tax, German tax and treaty coordination.
Lire le guideSelling U.S. securities while resident in Germany
Cost basis, move timing and capital gains.
Lire le guideInvestment planning before moving to Germany
Portfolio review before German residence begins.
Lire le guideAccompagnement bidirectionnel
Poursuivre avec le point de vue de TaxRep en Allemagne
Kapitalanlagen & Quellensteuern
German tax perspective on U.S. investments.
Accéder à taxrep.deRésidence et déménagement
Residence determines which investment rules apply.
Explore residencyDéclarations fiscales et rapports
FBAR, FATCA, Form 8621 and annual compliance.
Explorer les rapportsÉtats-Unis-Allemagne
Return to the cross-border hub.
Retour au hubConseils fiscaux États-Unis – Allemagne
Holding investments across both countries?
We coordinate investment taxation, PFIC exposure, withholding taxes, foreign tax credits and reporting.
Discuss your investment situation