German US Cross Border Inheritance Tax:

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Germany–US Cross-Border Inheritance Tax Hub

Last updated: 6 Nov 2025

Germany–US Cross-Border Inheritance Tax Hub

Central hub for Germany–US inheritance and estate tax matters: treaty allocation, § 21 ErbStG credits, valuation, filing coordination, planning, and practical workflows for real estate, business interests, and cross-border estates.

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How we work: The hub coordinates treaty allocation, §21 credit claims, timelines and documentation. National filings are delivered by our dedicated teams: 🇩🇪 German Inheritance Tax Service · 🇺🇸 US Estate / Inheritance Tax Service.

Topics in this hub

Planning

Allowances, 10-year rule, asset location, lifetime gifts, liquidity for US estate tax, what-if scenarios.

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Coordination & §21 Credits

Filing workflow, valuations (BewG vs. FMV), documentation, proof of foreign tax, timelines.

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Treaty (Germany–US)

Taxing rights, tie-breakers, situs allocation, credit method; interaction with §21 ErbStG.

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Real Estate & Business Assets

Property & company shares: valuation, §§13a/13b relief, US-situs, debt allocation, examples.

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Trusts & Foundations

US trusts under German law; foundation structuring & management in cross-border estates.

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Executor & Administration

International probate, German certificates, asset transfers, bank compliance, §21 evidence.

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Checklists & Documents

Bilingual checklists for Germany–US filings, valuations, assessments, and payment proofs.

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State Taxes (US)

State-level estate/inheritance taxes and how they interact with German assessments & credits.

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Examples & Calculations

Worked examples with and without §21, treaty allocation, multiple heirs; what-ifs.

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FAQ

Quick answers on residency, domicile, situs, §21, treaties, timelines, documentation.

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Helpful resources

Next steps: Use the topic pages above to deep-dive, then start coordination with our 🇩🇪 German Inheritance Tax Service or 🇺🇸 US Estate / Inheritance Tax Service.