Guide · English · To be published October 29, 2026

The American’s Guide to Germany

Wealth, Taxes and Estate Planning

A guide for Americans, meaning U.S. citizens and green card holders, who live in Germany or plan to move there. The United States taxes its citizens and green card holders on their worldwide income, and its citizens on their worldwide estates and gifts, wherever they live. Germany taxes its residents on their worldwide income and taxes inheritances and gifts whenever the giver or the recipient lives in Germany. The book explains how the two systems apply to the same person and the same assets, how the agreements between the two countries allocate taxing rights, and which decisions are best made before or soon after the move.

Forthcoming. To be published on October 29, 2026. Pre-orders are accepted now.

Author	Caroline Esche Ashford, PhD, JD, Attorney-at-Law, Rechtsanwältin
Publication date	October 29, 2026
Extent	About 440 pages
Language	English
Price	USD 300
Ordering	Pre-order through the form on this page or by email to info@clarisonpress.com

Pre-order Contents

Summary

1.Two tax systems apply to the same person. The book begins with the four status questions that decide which rules apply: citizenship, U.S. income tax residence, domicile for U.S. estate and gift tax, and German residence.
2.The three agreements between the two countries, the income tax treaty, the estate and gift tax treaty and the Social Security agreement, are applied throughout, including the saving clause and the special credit rule for U.S. citizens resident in Germany.
3.Entry and residence permits, German citizenship and dual citizenship are covered, together with the reason immigration status does not decide tax residence.
4.Income, investments and companies are examined under both systems: German income tax and the foreign tax credit, work and Social Security, the Investment Tax Act and the PFIC rules, U.S. retirement accounts after the German reform of 2025, German pensions and insurance, digital assets, the GmbH and the LLC, and real estate in both countries.
5.Family law is treated together with tax: matrimonial property regimes, the spouse who is not a U.S. citizen, divorce, children born abroad, health insurance and powers of attorney for both countries.
6.Estate planning joins the EU Succession Regulation, the German compulsory share and U.S. trusts with both transfer taxes and the ten-year rule of the estate and gift tax treaty. The book closes with estate settlement and inheritances, U.S. reporting obligations, the return to the United States and the exit tax.

Readership

The book is written for U.S. citizens and green card holders who live in Germany or plan to move there, and for their families: retirees, employees and executives posted to Germany, the self-employed and founders, couples in which one spouse is not a U.S. citizen, and the heirs of American families with assets in both countries.

It is written for readers with substantial assets, for whom the decisions on investments, real estate, trusts and succession carry the most weight.

Konstanz on Lake Constance, seen from above

The Ten Parts

Part I. Two Tax Systems: Citizenship, Residence and the Treaties

1How the United States and Germany Each Tax an American Living in Germany

2German Tax Residence: The Full-Time Move and the Vacation Home

3The Three Agreements Between the United States and Germany: The Income Tax Treaty, the Estate and Gift Tax Treaty and the Social Security Agreement

4U.S. Tax Filings from Germany and Ending State Tax Residence

5Before the Move: Timing and a Pre-Move Checklist

Part II. Entry, Visas and Residence Status

6Entry Without a Visa: The 90/180-Day Rule, the Entry/Exit System, ETIAS and Applying for a Residence Permit from Inside Germany

7Residence Permits for Employment, Self-Employment and Job Search: The EU Blue Card, the Skilled-Worker Permits, the ICT Card, the Opportunity Card and the Permit for the Self-Employed

8Residence Permits for Retirees, Persons of Independent Means and Family Members

9Permanent Residence, German Citizenship and Dual Citizenship, and Why Immigration Status Does Not Decide Tax Residence

III

Part III. Income Taxes and Social Security

10German Income Tax for the American Resident

11Avoiding Double Income Taxation: The Foreign Earned Income Exclusion, the Foreign Tax Credit and the Treaty Rules for U.S. Citizens

12Working in Germany: Employees, the Self-Employed and Remote Workers for U.S. Employers

13Founders and Executives: Stock Options, Restricted Stock, Qualified Small Business Stock and the German Tax on Shareholdings at Departure

14Social Security, the German Statutory Pension and the Totalization Agreement

Part IV. Investments, Retirement Savings and Companies

15How Germany Taxes Investment Income and How the German Tax Is Credited on the U.S. Return

16German and Other Non-U.S. Investment Funds: The PFIC Rules

17Holding Investment Accounts While Living in Germany: U.S. Brokers, German Banks and Currency

18U.S. Retirement Accounts in Germany: IRA, 401(k) and Roth Accounts After the German Reform of 2025

19German Pensions, German Life Insurance and Annuities Held by an American

20Cryptocurrency and Other Digital Assets

21Owning a Company: The German GmbH and the U.S. LLC

Part V. Real Estate

22Buying a Home or Vacation Property in Germany

23Owning, Renting Out and Selling German Property

24The U.S. Home and Other U.S. Real Estate During Residence in Germany

Part VI. Family, Health and Incapacity

25Marrying in Germany: Matrimonial Property Regimes and the Estate Plan

26The Spouse Who Is Not a U.S. Citizen

27Divorce When One Spouse Is American and the Couple Lives in Germany

28Children Born Abroad: Citizenship, Education Savings and Family Benefits

29Health Insurance, Long-Term Care Insurance, Medicare and Other Insurance

30Planning for Incapacity: Powers of Attorney and Health-Care Directives for Both Countries

VII

Part VII. Estate Planning, Gifts and Inheritance Tax

31Wills and the Choice of Law: The EU Succession Regulation, German Will Forms and Coordinated Wills

32The German Compulsory Share (Pflichtteil) and Planning for It

33Beneficiary Designations, TOD and POD Accounts and Joint Ownership Under German Law

34Moving to Germany with a U.S. Revocable or Irrevocable Trust

35The Beneficiary in Germany of a Parent’s U.S. Trust

36U.S. Estate and Gift Tax and German Inheritance and Gift Tax Compared

37The Estate and Gift Tax Treaty and the Ten-Year Rule for Americans Moving to Germany

38Lifetime Gifts Under Both Tax Systems

39Charitable Giving in Germany and the United States

40Art, Collectibles and Other Valuables: Moving Them to Germany, Giving Them and Leaving Them at Death

VIII

Part VIII. Estate Settlement and Inheritances

41Settling the Estate of an American Who Dies in Germany, and of a Spouse Who Is Not a U.S. Citizen

42Inheriting from a German Relative

43Inheriting U.S. Assets While Living in Germany

Part IX. U.S. Reporting Obligations

44Reporting German Accounts: FBAR, Form 8938 and Banking as a U.S. Person

45Foreign Trusts, Gifts, Funds and Companies: Forms 3520, 3520-A, 8621, 5471 and 8858

46Late Filings and Accidental Americans: The Streamlined Procedures and the Relief Procedures for Former Citizens

Part X. Returning to the United States or Giving Up U.S. Status

47Returning to the United States: The Checklist for Leaving Germany

48Giving Up U.S. Citizenship or a Green Card: The Exit Tax and Section 2801

Appendices

Appendix	Contents
A	Full-Time Resident and Part-Time Resident Compared
B	Annual Filing Calendar
C	The Three Agreements in Summary
D	German and English Glossary of Tax and Legal Terms
E	Pre-Move and First-Year Checklists
F	Key Figures for 2026
G	U.S. and German Forms at a Glance
H	About the Author and About Clarison Press

Pre-order

The American’s Guide to Germany is to be published on October 29, 2026. Price: USD 300 a copy. Each pre-order request is confirmed by email, with the shipping costs and the method of payment.

Contents and publication date may change. Trade and bulk orders: info@clarisonpress.com

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