German Inheritance Law

10/09/2026

Do you live in Germany, and does a parent in the U.S. have a revocable living trust? Then the speed of the trust administration after your parent's death can decide how much German inheritance tax you pay.

A trust that pays out promptly is usually taxed once, as an ordinary inheritance from your parent.
A trust that keeps holding the house or pays you in instalments for a year or two can be treated in Germany as a separate foreign entity, and each payment may be taxed again.

In our new article: what German courts have said, and six drafting points your parent's U.S. estate planner can build into the trust today, while it can still be amended.

Read the full article: https://www.germaninheritancelaw.us/germany-residents-inheriting-from-the-us/parents-revocable-trust-german-inheritance-tax-why-speed-matters/

10/09/2026

Living in Germany and named in a parent's US trust? German tax law cares about timing. A trust that pays out quickly is taxed very differently from one that holds the house for two years. Here's what to discuss with your US attorney – before the trust becomes irrevocable: https://www.germaninheritancelaw.us/german-inheritance-tax/us-revocable-trust-german-inheritance-tax/

09/11/2026

Your U.S. trust has a beneficiary in Germany? Then it also has to pass German tax law – and Germany does not know trusts. What the trust does after the settlor's death can decide whether your family is taxed once or on every distribution.

New on the blog:

A U.S. revocable trust can trigger German inheritance tax for heirs in Germany. How Germany classifies trusts – and why timing after death matters.

09/08/2026

🇩🇪🇺🇸 This Monday: a free online hour on inheriting from Germany.

"Inheriting Assets in Germany? Here's What U.S. Heirs Need to Know"

I'm a German attorney in Denver, and most of my clients found me the same way: someone in the family died in Germany, and suddenly nobody knew what to do next.

In one hour I'll walk through it in plain English — the Erbschein, what the German probate court expects from you, how German banks release money to heirs abroad, and where German and U.S. inheritance tax collide.

📅 Monday, September 14, 2026
🕖 7:00–8:00 PM ET (6 CT · 5 MT · 4 PT)
💻 Online — link sent after registration
🎟️ Free: https://germansociety.app.neoncrm.com/nx/portal/neonevents/events?path=%2Fportal%2Fevents%2F50950

Hosted by the German Society of Pennsylvania. Bring your questions — there's time for them at the end.

👉 Know someone with family or property in Germany? Please share this post.

General information, not legal advice. Attorney advertising.

09/04/2026

🇩🇪🇺🇸 Free webinar — Monday, September 14

"Inheriting Assets in Germany? Here's What U.S. Heirs Need to Know"

A house in Munich. A bank account in Hamburg. A letter from a German court that no one in the family can read.

If you have inherited — or expect to inherit — from relatives in Germany, this hour is for you.

German inheritance law works nothing like American probate. There is usually no executor. The estate passes to the heirs directly, together with the debts. Deadlines run quietly in the background. And two tax authorities want to hear from you.

I'll walk you through the whole process in plain English: the Erbschein, what the German probate court expects from you, how German banks release funds to heirs abroad, and where German and U.S. inheritance tax collide.

📅 Monday, September 14, 2026
🕒 7:00–8:00 PM ET (6 CT · 5 MT · 4 PT)
💻 Online — link sent after registration
🎟️ Free: https://germansociety.app.neoncrm.com/nx/portal/neonevents/events?path=%2Fportal%2Fevents%2F50950

Hosted by The German Society of Pennsylvania — facebook.com/GermanSocietyPA
Questions welcome at the end — bring them.

👉 Know someone with family or property in Germany? Please share this post with them.

General information, not legal advice. Attorney advertising.

GSP seeks to further the understanding of German contributions to the growth of the United States.

08/28/2026

Yesterday evening I ran a webinar for American and German-American families with property, heirs or children in both countries — an hour on what actually happens to an estate that sits in two legal systems. 30 of you came, and many stayed long past the end to ask questions. Thank you. It was one of the best evenings I have had doing this work.

Here is the moment it went quiet.

A widow inherits €600,000 from her husband. Passing to her directly, she is in German tax class I: €500,000 tax-free — in my example, about €11,000 in German inheritance tax.

The same €600,000, from the same husband, arriving through a US trust: German law has no trust of its own, so the payout can be treated as coming from a foreign entity — tax class III. Only €20,000 tax-free, rates from 30%. In the same example, about €174,000.

Nobody did anything wrong. The trust was good US planning. It just never met German tax law.

That is really the whole point of cross-border planning: not two good plans, but one plan that works in both countries.

If you missed it: we are doing it again in December. I am keeping a list so nobody has to find out about it by accident in a feed. Message this page, or email [email protected] with the word LIST, and you are on it.

And if you know an American family with something in Germany who should have been in that room: please send this to them. That is honestly how most people find me.

General information for education — not individual legal or tax advice.

08/24/2026

3 days to go — don't miss it. 🇩🇪🇺🇸

On Thursday, 27 August, I'm running my free webinar for American families with German ties: what happens to your estate when your life spans two legal systems.

🗓️ Thursday, 27 August 2026
🕕 18:00–19:00 Berlin · 12:00 pm ET · 9:00 am PT
💻 In English, on Microsoft Teams — free, registration required

Register here: https://www.eventbrite.com/e/your-family-your-estate-german-inheritance-law-for-us-citizens-free-webinar-tickets-1989798732573

General information, not legal advice. Bring your questions.

Know someone with a house, an account, or family in Germany? Tag them or pass this on — Thursday comes fast.

Free webinar (in English) on wills, guardianship, medical directives & US–Germany inheritance tax for Americans with German ties.

08/14/2026

She picked out the sunglasses herself. She wears them in the car, indoors, and — twice now — in the bath.

I take a lot of photos like this one. And every so often one of them stops me, because I do this for a living and I still catch myself avoiding the question underneath it:

If I weren’t here tomorrow, who would raise her?

I write that document for other families. I know the paragraph number by heart. And I still found it easier to draft it for a client on a Tuesday morning than to sit down at my own kitchen table and write the name down.

Here is the part that makes it harder for families like mine, with one foot in Germany and one in Colorado: it is not enough to write it once.

Which country’s court decides is driven by where your child actually lives — not by the passport in the drawer. And because the US never ratified the 1996 Hague Convention on the protection of children, a German document does not automatically travel to an American court, and an American one does not travel to Germany. Most cross-border families need one on each side, naming the same people.

If you have been meaning to do this for months: I understand completely. I was you. It is one uncomfortable afternoon, and then it is done, and you get to stop carrying it around.

08/14/2026

This is my daughter. She picked out the sunglasses herself. They are non-negotiable and, as far as she is concerned, weather-independent.

I am a German attorney based in the US. I spend my working days on German estates — probate courts, Erbschein applications, inheritance tax files. And of everything I draft, the one document I put off longest in my own life was the one that decides who would raise this child if I weren't here.

Not because it is complicated. Because 🇺🇸🇩🇪
For families living between Germany and the US, there is a second layer, and it is the part almost nobody knows about. Which country's court would decide is generally determined by where the child habitually lives — not by which passport they hold, and not by where the document was signed. And because the United States never ratified the 1996 Hague Convention on the protection of children, a German appointment is not automatically recognised by a US court, and the reverse is just as true.

So the honest answer for most German-American families is: you need a document on each side, and they need to name the same people.

There is also a formal trap on the German side that catches nearly everyone. A guardian nomination only counts if it is written the way a will is written — entirely by hand and signed, or before a notary. A typed and signed page, however carefully drafted, is void. I have had to tell people that after the fact, and it is a terrible conversation.

If you have been meaning to sort this out for a while, this is your nudge. It is one afternoon. And it is the softest, most important thing you will ever put in writing.

Know a German-American family with small children? Send this along, or tag them.

08/11/2026

A little story, and then an invitation.

Earlier this summer I held in-person seminars in Berlin and Hamburg on German inheritance law, for families with one foot in Germany and one in the US. Both times, the most useful part wasn't my talk — it was the half hour afterwards, when people finally asked the questions they'd been carrying around for months. What do we do with the apartment? Why does the bank in Germany keep asking for an Erbschein (the German certificate of inheritance)? Does my American will cover anything over there?

And nearly everyone said the same thing: my family back in the States needed to hear this.

So, on popular demand, we're doing it again — online, and free.

Your Family. Your Estate. — German Inheritance Law for US Citizens
Thursday, August 27, 2026
6:00–7:00 pm German time · 12:00 pm ET · 9:00 am PT
In English, via Microsoft Teams. Free, RSVP required.

One hour on German succession law and wills, cross-border estate planning under the EU Succession Regulation, guardianship for your children, medical directives and powers of attorney, and inheritance tax across the Atlantic. No legal background needed, and all questions are welcome. This is general information, not legal advice for your particular situation.

Register here: https://www.eventbrite.com/e/your-family-your-estate-german-inheritance-law-for-us-citizens-free-webinar-tickets-1989798732573

Know someone with family property or a bank account in Germany? Tag them below or send this along — it's the kind of thing people wish they'd known a year earlier.

Free webinar (in English) on wills, guardianship, medical directives & US–Germany inheritance tax for Americans with German ties.