hTTi

Sorry for your loss navigating this across two systems adds a layer of complexity most people don’t expect.

What you’re dealing with here is not just an inheritance reporting question, but a cross-border structuring decision, especially given the mix of life insurance and a 401k.

A few points ...

The challenge here is less about finding a “Steuerberater” and more about finding the right cross-border capability.

Most German Steuerberater:
• Do not handle US filings (FBAR, Form 8938, etc.)
• Focus on German compliance only
• Are not set up for ongoing US–Germany coordination

On the other ...

This situation usually gets framed incorrectly as a “totalization agreement issue,” but that’s only one part of it.

What you’re dealing with is a combination of:

1. Social security coverage (US vs. Germany)
The 5-year limit under the Totalization Agreement is tied to remaining in the US system via ...