Cross-Border Tax Knowledge
Germany–United States Tax
Cross-border tax issues between Germany and the United States, structured by tax topic, typical situations and detailed technical guidance. TaxRep combines the German and U.S. tax perspectives within one coordinated cross-border analysis.
Orientation
Find Germany–U.S. tax guidance by situation and topic
Germany–U.S. tax matters frequently involve several tax systems, reporting obligations and treaty provisions at the same time.
German tax residence, German-source income, tax returns, investments, businesses and inheritance matters must often be coordinated with U.S. citizenship-based taxation, Green Card status, federal reporting and the Germany–U.S. tax treaties.
The knowledge base therefore uses three levels: topics for the technical structure, situations for concrete life and business cases, and technical guides for individual tax questions.
Need the U.S. tax perspective as well?
TaxRep USA covers U.S. federal taxation and international U.S. reporting. In cross-border engagements, the German and U.S. tax consequences are coordinated as parts of the same case.
Topics
Germany–U.S. tax by topic
These topic hubs form the technical structure of the Germany–United States knowledge base.
Tax Residency & Moving
German residence, moving to or from Germany, Green Cards, the Substantial Presence Test, treaty residence and moving-year issues.
Explore topicEmployment & Social Security
Employment income, remote work, assignments, German payroll tax, U.S. Social Security, German social insurance and the Totalization Agreement.
Explore topicInvestments & Withholding Taxes
Stocks, ETFs, investment funds, brokerage accounts, dividends, U.S. withholding tax, German investment taxation and cross-border capital income.
Explore topicBusinesses & Ownership Interests
U.S. LLCs, corporations and partnerships, German GmbHs and UGs, entity classification, CFC rules and place of management.
Explore topicReal Estate
Rental income, property sales, depreciation, U.S. state taxation, FIRPTA, German tax reporting and treaty allocation.
Explore topicPensions & Retirement
German pensions, U.S. Social Security, 401(k), IRA, Roth IRA and the cross-border taxation of retirement benefits.
Explore topicEstate & Gifts
German inheritance and gift tax, U.S. Estate Tax, Gift Tax, U.S.-situs assets, trusts and cross-border estate planning.
Explore topicTax Returns & Reporting
German and U.S. tax returns, FBAR, FATCA, international information forms, Foreign Tax Credits and late-filing issues.
Explore topicHow the knowledge base works
Topics provide the structure. Situations connect the topics.
A single cross-border case often involves several topics. A move, a U.S. employer, an investment portfolio or an international company therefore requires a coordinated analysis.
- Topics for technical classification
- Situations for typical cross-border cases
- Technical guides for individual questions
- Connections between German and U.S. tax rules
Situations
Typical Germany–U.S. cross-border situations
These guides bring together the tax topics that commonly arise in specific personal and business situations.
U.S. Person in Germany With a U.S. Brokerage Account
A U.S. citizen or other U.S. taxpayer living in Germany with a U.S. brokerage account: dividends, interest, capital gains, cost basis and Foreign Tax Credits.
View situationMoving from Germany to the United States
Planning the move, ending or continuing German tax liability, beginning U.S. tax residence, investments, pensions and the moving year.
View situationMoving from the United States to Germany
Start of German tax liability, continuing U.S. taxation, U.S. investment accounts, retirement plans, businesses and the year of arrival.
View situationU.S. Employer with an Employee in Germany
Remote work from Germany, employment income, German payroll, social security, the Totalization Agreement and potential employer obligations.
Explore topicGerman Resident with a U.S. Business
U.S. LLC, corporation or partnership with a German-resident owner, including entity classification, profit attribution and place of management.
Explore topicU.S. Person with a German Company
German GmbH or UG ownership by a U.S. person, including Form 5471, CFC, GILTI, distributions and German corporate tax.
Explore topicU.S. Investments with German Tax Residence
U.S. stocks, ETFs, brokerage accounts, dividends, withholding tax, German taxation and investment-fund issues.
Explore topicU.S. Real Estate with German Tax Residence
Rental income, U.S. federal and state tax, German reporting, property sales, FIRPTA and treaty allocation.
Explore topicU.S. Retirement Income in Germany
Social Security, 401(k), IRA, Roth IRA and U.S. pension income with German tax residence.
View situationTechnical Guides
Specific Germany–U.S. tax questions
The following cards link only to existing detailed guides. Topic hubs remain in the Topics section and are not repeated here as if they were technical articles.
Moving Year Between Germany and the United States
German tax liability, treaty residence, income allocation and coordinated tax returns in the year of a cross-border move.
Read guideU.S. Dividends for German Residents
U.S. withholding tax, treaty rate, Form W-8BEN, German taxation and the German foreign-tax credit.
Read guideU.S. Broker While Resident in Germany
German tax reporting, broker statements, cost basis, euro conversion and Anlage KAP for a U.S. brokerage account.
Read guideStock Sales and Capital Gains
German gain calculation, U.S. brokerage data, euro conversion, loss offset and treaty allocation of capital gains.
Read guide401(k) with German Tax Residence
Treaty pension-plan treatment, tax deferral, distributions and German taxation under Section 22 No. 5 EStG.
Read guideTraditional IRA with German Tax Residence
Treaty recognition, tax deferral, contribution history, rollovers and German taxation of later distributions.
Read guideU.S. Person in Germany: Tax & Compliance
Form 1040, Foreign Tax Credit, FBAR, Form 8938 and other cross-border reporting obligations for U.S. persons in Germany.
Read guideU.S. Person with a German GmbH
Form 5471, CFC rules, Subpart F, Section 951A, German corporate taxation and coordinated cross-border compliance.
Read guideLooking for a specific issue?
Browse the knowledge base for terms such as PFIC, FBAR, Form 5471, 401(k), LLC, FIRPTA or Foreign Tax Credit.
Tools & Checklists
Prepare your cross-border tax situation
Checklists and self-assessment tools can help identify important tax connections early and organize the information needed for a consultation or tax return.
Germany–U.S. Tax Advice
Does your tax situation involve both countries?
We advise individuals and businesses on cross-border tax matters between Germany and the United States. German and U.S. tax consequences, treaty provisions, foreign tax credits, tax returns and reporting obligations are coordinated as one cross-border case.
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