For United States estate planners, CPAs, plan administrators and custodians whose client, or whose client’s beneficiary, lives in Germany and draws on an American retirement account.
What the guide covers
- Why the income tax treaty, and not the Code, assigns the pension to Germany under Article 18.
- The section 1441 withholding and the Form W-8BEN that reduce it to nothing.
- How Germany taxes the distribution under section 22 number 5 EStG, before and after the 2025 reform.
- The Roth account, the annuity, and the timing of the move.
- The United States citizen in Germany under the saving clause.
- The inherited account under the estate tax treaty and German inheritance tax.
The full title
IRA and 401(k) Distributions to a Beneficiary in Germany: U.S. Withholding, the Treaty That Reduces It to Nothing, and the German Taxation of the Distribution After the 2025 Reform
The guide is sent as a PDF against an email address. The link that arrives is valid for twenty-four hours.
Request the PDFThe firm is led by attorney Caroline Esche Ashford, PhD, JD. A graduate of Columbia University Law School, her practice focuses on international estate planning and the cross-border taxation and administration of estates and trusts, including the taxation of American retirement distributions paid to beneficiaries in Germany. Dr. Ashford is also licensed to practice law in Germany. She advises in French and German as well as English.
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