What a U.S. citizen living in Germany, or planning the move, faces on giving up U.S. citizenship: the expatriation date, the covered expatriate tests, the deemed sale, pensions and retirement accounts, Germany's treatment of the deemed sale, the two conventions, section 2801 and the compliance calendar, with a worked example.
How Germany treats the section 877A deemed sale of a covered expatriate: the § 17 EStG value linkage, the treaty election, the timing trap and what to do first.
Article 4(3) of the US-Germany estate tax treaty keeps you US-domiciled for ten years. Who it covers, who it misses, and what to do before year eleven.
For individuals who split their time between Germany and the United States, one of the most consequential legal and tax questions is often deceptively simple: Where is the individual actually tax resident? This issue becomes particularly complex where a person: owns residences in both Germany and the United States, spends substantial time in both countries, … Continue reading Determining Fiscal Domicile Under Article 4 of the Germany–U.S. Double Taxation Treaty: Dual Residences, Cross-Border Estates, and the “Center of Vital Interests”
Joint wills and testamentary contracts are recognized testamentary dispositions in Germany, beyond the individual will.
Germany-USA: Law, Tax, Finance 