Cross-Border Tax Guide
Germany–United States Tax
German–U.S. tax questions often require both domestic tax systems and the Germany–U.S. tax treaty. On taxrep.de, the German tax perspective is primary; the corresponding U.S. rules are linked to taxrep.us.
One Situation · Two Tax Systems
Start With German Tax Law, Then Coordinate the U.S. Side
German residence, unlimited or limited tax liability, German-source income and German reporting are analyzed first. U.S. citizenship, Green Card status, U.S. residency and U.S. information reporting are then coordinated through the corresponding U.S. pages.
Domestic law stays on the country domain. Bilateral pages connect the two systems without duplicating the national technical rules.
Tax Topics
Explore Germany–U.S. Tax by Topic
01 Residency & Moving
Residence, departure, arrival, treaty residence and moving-year issues.
Explore topic02 Employment & Social Security
Employment, remote work, assignments, payroll and social-security coordination.
German topic hub to follow03 Investments & Withholding Taxes
Brokerage accounts, dividends, gains, ETFs, funds and withholding taxes.
German topic hub to follow04 Businesses & Ownership Interests
LLCs, GmbHs, partnerships, corporations and cross-border ownership.
German topic hub to follow05 Real Estate
German and U.S. property, rental income, depreciation and sales.
German topic hub to follow06 Pensions & Retirement
German pensions, U.S. Social Security, 401(k), IRA and retirement distributions.
German topic hub to follow07 Estate & Gifts
Cross-border inheritances, gifts and estate/gift tax.
German topic hub to follow08 Tax Returns & Reporting
German returns, Form 1040, FBAR, FATCA and coordinated compliance.
German topic hub to followCommon Situations
Start With the Actual Cross-Border Situation
Moving From the U.S. to Germany
German residence, worldwide taxation and U.S. income after the move.
View situationMoving From Germany to the U.S.
Ending German residence and remaining German-source income.
View situationU.S. Person Living in Germany
German unlimited tax liability combined with continuing U.S. filing.
View situationResident Under Both Systems
Article 4 treaty residence and tie-breaker rules.
View situationMoving During the Tax Year
German tax liability, treaty residence and moving-year coordination.
View situationKeeping a Home in Germany
When § 8 AO residence can continue after moving abroad.
Read foundationTechnical Guides
German Tax-Law Foundations
German Tax Residence
Residence under § 8 AO.
Read guideHabitual Abode
Physical presence under § 9 AO.
Read guideUnlimited Tax Liability
Worldwide income and § 1 EStG.
Read guideLimited Tax Liability
German-source income under § 49 EStG.
Read guideLeaving Germany
Ending residence and departure-year taxation.
Read guideResidence After Moving Abroad
Retained German home after departure.
Read guideTreaty Residence
Article 4 and tie-breaker rules.
Read guideMoving-Year Tax Return
German taxation in the year of a move.
Read guideConnected Perspective
Continue With the U.S. Side on taxrep.us
This page is Germany-first. U.S. federal residence, citizenship taxation, Green Card rules and U.S. reporting belong on taxrep.us.