Cross-Border Tax Guide
United States–Germany Tax
U.S.–German tax issues rarely belong to only one country. Residency, employment, investments, companies, real estate, pensions, estates and annual filing obligations often have to be coordinated under both domestic tax systems and the U.S.–Germany tax treaty.
Panoramica
One cross-border situation, two tax systems
The right answer depends first on the taxpayer's residence, citizenship, immigration status, income sources and legal structures — and then on how Germany and the United States interact.
U.S. citizens and other U.S. persons can remain subject to U.S. tax and reporting rules after moving to Germany. At the same time, German residence can create German taxation of worldwide income. Treaty relief, foreign tax credits, social-security coordination and entity classification therefore have to be considered together.
Tax Topics
Explore U.S.–Germany tax by topic
Residenza e Trasloco
Moving between the United States and Germany, dual residence, treaty residence, arrival and departure years.
Explore topicLavoro e previdenza sociale
Employment income, remote work, assignments, self-employment, payroll and U.S.–German social-security coordination.
Explore topicInvestments & Withholding Taxes
Brokerage accounts, dividends, interest, capital gains, ETFs, mutual funds, PFIC issues and withholding taxes.
Explore topicBusinesses & Ownership Interests
LLCs, German GmbHs, partnerships, corporations, founders and cross-border owner reporting.
Explore topicImmobili
German or U.S. property, rental income, financing, depreciation, sales and ownership through companies.
Explore topicPensions & Retirement
Social Security, German statutory pensions, 401(k)s, IRAs, company pensions and retirement distributions.
Explore topicPatrimonio e Donazioni
Cross-border inheritances, gifts, U.S. estate and gift tax, German inheritance and gift tax and reporting obligations.
Explore topicDichiarazioni fiscali e rendiconti
U.S. Form 1040, German income tax returns, FBAR, FATCA, foreign entities and coordinated annual compliance.
Explore topicSituazioni Comuni
Start with your actual cross-border situation
Cittadino statunitense che si trasferisce in Germania
German residence, continued U.S. filing, investments, employment and pre-move planning.
Visualizza situazioneGerman resident with U.S. citizenship
Coordinated U.S. and German annual tax returns, foreign tax credits and reporting.
Visualizza situazioneUn tedesco che si trasferisce negli Stati Uniti
Departure from Germany, U.S. residency, investments, pensions and remaining German assets.
Visualizza situazioneU.S. LLC with German-resident owner
German entity classification, U.S. reporting, permanent-establishment and owner-level taxation.
Visualizza situazioneGerman GmbH with U.S. owner
German company taxation combined with U.S. international information reporting and possible CFC considerations.
Visualizza situazioneU.S. investments after moving to Germany
Brokerage accounts, capital gains, dividends, ETFs and fund classification after German residence begins.
Visualizza situazione401(k) or IRA while living in Germany
Contributions, distributions, treaty treatment and coordination with German taxation.
Visualizza situazioneInheritance between Germany and the U.S.
Estate and inheritance taxation, reporting, basis documentation and cross-border transfers.
Visualizza situazioneGuide tecniche
Key U.S.–Germany tax questions
Quando ha inizio la residenza fiscale in Germania?
Residence, habitual abode and the first German tax year.
Leggi la guidaU.S.–Germany treaty residence and dual residence
How domestic residence and treaty residence interact.
Leggi la guidaForeign tax credits for U.S. taxpayers in Germany
Coordinating German income tax with the U.S. Form 1116 system.
Leggi la guidaGerman and European funds for U.S. taxpayers
Why PFIC analysis matters before buying non-U.S. funds.
Leggi la guidaHow Germany taxes a U.S. LLC
Why U.S. classification does not automatically determine German classification.
Leggi la guidaFBAR and FATCA for Americans in Germany
Foreign financial accounts and U.S. information reporting.
Leggi la guidaU.S.–Germany social-security coordination
Employment, self-employment and coverage under the Totalization Agreement.
Leggi la guidaU.S. retirement accounts while resident in Germany
401(k), IRA and retirement distributions across both tax systems.
Leggi la guidaConnected Country Perspectives
The same cross-border case viewed from both sides
U.S. tax perspective
U.S. federal filing, citizenship-based taxation, foreign tax credits, FBAR/FATCA and U.S. international reporting.
Explore U.S. tax & reportingGerman perspective
German residence, German income taxation, entities, investments and German compliance for U.S.–German cases.
Apri taxrep.deU.S.–Switzerland
The parallel cross-border hub for U.S. taxpayers, investors and families with Swiss connections.
Explore U.S.–SwitzerlandTaxRep U.S.
Return to the TaxRep U.S. homepage for national and cross-border tax services.
Back to taxrep.usConsulenza fiscale USA-Germania
Need one coordinated answer for both countries?
We help individuals, founders, investors and families identify the U.S. and German tax consequences of the same cross-border situation and coordinate planning and compliance across both systems.
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