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.
Overview
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
Residency & Moving
Moving between the United States and Germany, dual residence, treaty residence, arrival and departure years.
Explore topicEmployment & Social Security
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 topicReal Estate
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 topicEstate & Gifts
Cross-border inheritances, gifts, U.S. estate and gift tax, German inheritance and gift tax and reporting obligations.
Explore topicTax Returns & Reporting
U.S. Form 1040, German income tax returns, FBAR, FATCA, foreign entities and coordinated annual compliance.
Explore topicCommon Situations
Start with your actual cross-border situation
U.S. citizen moving to Germany
German residence, continued U.S. filing, investments, employment and pre-move planning.
View situationGerman resident with U.S. citizenship
Coordinated U.S. and German annual tax returns, foreign tax credits and reporting.
View situationGerman moving to the United States
Departure from Germany, U.S. residency, investments, pensions and remaining German assets.
View situationU.S. LLC with German-resident owner
German entity classification, U.S. reporting, permanent-establishment and owner-level taxation.
View situationGerman GmbH with U.S. owner
German company taxation combined with U.S. international information reporting and possible CFC considerations.
View situationU.S. investments after moving to Germany
Brokerage accounts, capital gains, dividends, ETFs and fund classification after German residence begins.
View situation401(k) or IRA while living in Germany
Contributions, distributions, treaty treatment and coordination with German taxation.
View situationInheritance between Germany and the U.S.
Estate and inheritance taxation, reporting, basis documentation and cross-border transfers.
View situationTechnical Guides
Key U.S.–Germany tax questions
When does German tax residence begin?
Residence, habitual abode and the first German tax year.
Read guideU.S.–Germany treaty residence and dual residence
How domestic residence and treaty residence interact.
Read guideForeign tax credits for U.S. taxpayers in Germany
Coordinating German income tax with the U.S. Form 1116 system.
Read guideGerman and European funds for U.S. taxpayers
Why PFIC analysis matters before buying non-U.S. funds.
Read guideHow Germany taxes a U.S. LLC
Why U.S. classification does not automatically determine German classification.
Read guideFBAR and FATCA for Americans in Germany
Foreign financial accounts and U.S. information reporting.
Read guideU.S.–Germany social-security coordination
Employment, self-employment and coverage under the Totalization Agreement.
Read guideU.S. retirement accounts while resident in Germany
401(k), IRA and retirement distributions across both tax systems.
Read guideConnected Country Perspectives
The same cross-border case viewed from both sides
U.S. perspective
U.S. federal filing, citizenship-based taxation, foreign tax credits, FBAR/FATCA and U.S. international reporting.
Stay on taxrep.usGerman perspective
German residence, German income taxation, entities, investments and German compliance for U.S.–German cases.
Open taxrep.deU.S.–Switzerland
The parallel cross-border hub for U.S. taxpayers, investors and families with Swiss connections.
Explore U.S.–SwitzerlandAll Tax Guides
Browse national and cross-border tax topics across the TaxRep network.
View tax guidesU.S.–Germany Tax Advice
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.
Discuss your U.S.–Germany case