Germany taxes the acquisition by each beneficiary. If either decedent or beneficiary is German-resident, Germany usually taxes worldwide assets; otherwise only German-situs assets. The US federal estate tax applies based on the decedent, with US-situs and citizen/green-card rules; states may add estate or inheritance taxes. See Treaty overview.

Germany can credit foreign death duties paid on the same foreign asset slice included in the German assessment. The credit is limited to the German tax attributable to that slice. You’ll need foreign assessments and proof of payment, plus a situs & allocation memo. Start with our Coordination & §21 and the checklists.

Often yes, if the spouse/partner (or a child up to 200 m²) acquires and self-occupies the home for ~10 years. Early sale or no self-use risks clawback. See Real estate & business.

Relief of 85% or 100% may apply to qualifying business assets/shareholdings. Germany’s taxable base drops; US valuation remains FMV. Maintain wage-sum and asset-mix tests to avoid clawback. Coordinate appraisals and relief exhibits. Details: Real estate & business.

Yes—state death taxes can be part of the foreign tax paid on the same slice and may be creditable within the §21 ceiling. Keep separate assessments and payment proofs. See US state taxes.

Germany analyzes substance over form: who controls the assets and when do beneficiaries acquire enforceable rights? Revocable grantor trusts may be viewed as transparent; discretionary trusts require a vesting analysis. Consider a foundation (Stiftung) where predictability is needed. More: Trusts & foundations · Foundation structuring.

Plan early: align domicile, manage situs, use lifetime gifts, structure with predictable vehicles (e.g., foundations), and draft coordinated wills. Run what-ifs for treaty and §21 outcomes. See Planning.

Deadlines vary; interest exposure can arise if foreign tax is paid late relative to the German assessment. Sequence payments and submit a complete §21 pack early to minimize interest. Our executor guide covers practical timelines.

Yes—start with our German calculator, then we build §21 per-country credit worksheets and a FMV ↔ BewG reconciliation memo. See examples & calculations.

Pick someone with cross-border experience or appoint a professional executor to coordinate filings, appraisals, and §21 credits. Learn more in Executor & administration or engage our partner for international executor services.