German taxes for US inheritance

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nyjxwqwn
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German taxes for US inheritance

Post by nyjxwqwn »

Hi Everyone,

About 15 years ago, my mother in the US (Massachusetts) transferred the deed of her house to a Trust, with myself and my siblings as beneficiaries. She died a few years ago, and the terms of the trust will be met soon so that my brothers and I can sell the house.

I now live in Germany and am a tax payer here. I am still a US citizen, but not yet a German citizen.

I guess that even though I'm receiving the property as a beneficiary of the Trust, this is still considered an inheritance. From my research on inheritance tax in the US, it seems that I am not liable for any tax in the US, as the value of the house is far below the thresholds I've seen (a few hundred thousand $).

But, as we pay taxes for everything here in Germany, I assume I will be here. Can anyone advise on this situation? Especially if there's anything I can/should do to try to limit my tax liability?

Thanks!
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PandaMunich
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Re: German taxes for US inheritance

Post by PandaMunich »

nyjxwqwn wrote: Sat Feb 01, 2025 6:38 pm About 15 years ago, my mother in the US (Massachusetts) transferred the deed of her house to a Trust, with myself and my siblings as beneficiaries. She died a few years ago, and the terms of the trust will be met soon so that my brothers and I can sell the house.

I now live in Germany
Germany ignores trusts.
--> you have to pay inheritance tax at the moment the person dies.

If you were not living in Germany when your mother died, Germany does not have any taxation rights on this inheritance.
If you were living in Germany at the moment of her death, then as her child, the first 400,000€ of your inheritance are free of inheritance tax if she died in 2009 or later (if she died before, only 205,000€ were tax-free): https://www-buzer-de.translate.goog/ges ... r_pto=wapp
Though you did say she was alive 15 years ago, so the tax-free allowance in your case is 400,000€.

Please note that if you then invested that inheritance, you will of course have to pay German income tax on the worldwide interest, dividends or whatever income that inheritance generates.
nyjxwqwn
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Re: German taxes for US inheritance

Post by nyjxwqwn »

Thank you PandaMunich for such a prompt and helpful reply!
Sebastes
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Re: German taxes for US inheritance

Post by Sebastes »

I found this article to be helpful for understanding the basics.
https://www.expatica.com/de/finance/tax ... ny-108115/
However it would be best to consult a German tax specialist for specific questions.
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Alberto
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Re: German taxes for US inheritance

Post by Alberto »

Sebastes wrote: Sun Feb 02, 2025 1:43 pm it would be best to consult a German tax specialist
By now this should be clear already: PandaMunich actually IS a German tax specialist.
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