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.