United States–Germany Topic
Tax Residency & Moving Between the U.S. and Germany
A move between the United States and Germany affects two different tax systems. On taxrep.us, the U.S. tax perspective is the primary focus. German-law issues are linked directly to the corresponding English pages on taxrep.de.
One fact pattern · two tax systems
Start with the Actual Situation, Then Separate the Two National Perspectives
U.S. tax residence is determined first under U.S. domestic law. German tax residence is determined separately under German domestic law. Only after that do treaty residence and bilateral coordination become relevant.
This page is the U.S. entry point for residency and moving issues between the two countries. General U.S. tax-law topics are explained on taxrep.us, while German-law foundations are linked to the English German knowledge base on taxrep.de.
Your Situation
Which Situation Applies to You?
Start with the actual fact pattern. Each situation guide connects the relevant U.S. rules with the corresponding German perspective and treaty coordination.
U.S. Citizen Moving to Germany
Continuing U.S. tax filing, foreign tax credit and reporting issues after becoming resident in Germany.
Open guideGerman Moving to the United States
When U.S. tax residency begins, how the moving year is handled and which U.S. filing obligations follow.
Open guideU.S. Citizen Living in Germany
U.S. worldwide taxation, Form 1040, foreign tax credits and international reporting while German tax residence continues.
Open guideKeeping a U.S. Home After Moving to Germany
Federal tax residence, state domicile and the significance of retaining a home in the United States after the move.
Open guideResident Under Both U.S. and German Law
Where both systems treat the individual as resident, treaty residence and the tie-breaker rules may become relevant.
Explore treaty residenceMoving During the Tax Year
Residency starting and termination dates, resident and nonresident periods, and possible dual-status filing.
Open guideU.S. Tax Perspective
U.S. Tax-Law Foundations Relevant to These Cases
General U.S. tax-law topics belong on taxrep.us and are linked from the bilateral Germany–U.S. guides where they are relevant.
When Does U.S. Tax Residency Begin?
Green Card status, the Substantial Presence Test, the First-Year Election and the rules that determine when U.S. federal tax residency begins.
Read U.S. tax guideSubstantial Presence Test
How days of physical presence in the United States can create U.S. federal tax residency for a non-U.S. citizen.
Read U.S. tax guideGreen Card & U.S. Tax Residency
How lawful permanent resident status affects U.S. tax residency before and after a cross-border move.
Read U.S. tax guideU.S. Citizens Abroad
Why U.S. citizens generally remain subject to U.S. federal tax filing after becoming resident in Germany.
Read U.S. tax guideMoving-Year & Dual-Status Returns
U.S. filing consequences where resident and nonresident periods occur in the same calendar year.
Read U.S. tax guideU.S.–Germany Tax Treaty Residence
Treaty residence becomes relevant where both countries treat an individual as resident under their domestic law.
Read treaty guideThe Other Side of the Case
German Tax Perspective
For the German tax side, continue on taxrep.de
German residence, habitual abode, unlimited and limited tax liability, and residence termination are explained in the English German-law knowledge base on taxrep.de.
Residence under German Tax Law
When a dwelling can establish German tax residence.
Read on taxrep.deHabitual Abode
When physical presence in Germany can create unlimited German tax liability.
Read on taxrep.deGerman Residence After Moving Abroad
When a retained German home can cause German tax residence to continue.
Read on taxrep.deU.S.–Germany Tax Advice
Planning a Move Between the U.S. and Germany?
We review U.S. residency, moving-year filing, continuing U.S. obligations, treaty coordination and the interaction with German tax residence.
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