U.S.–Germany wealth planning: accounts, pensions, and timing

Determine residence before applying treaty conclusions

Begin with each country’s domestic residence rules. If both countries treat the person as resident, review the treaty’s residence provisions and obtain advice on the facts supporting the conclusion.

The outcome can influence which treaty articles apply, but U.S. citizens must also consider the treaty saving clause and its exceptions. Treaty language should be read with its protocols and technical explanations.

Classify every pension and investment wrapper

List U.S. retirement accounts, German statutory and occupational benefits, private pensions, insurance products, and taxable investments. Record contributions, employer funding, vesting, distribution choices, and the expected country of residence when benefits begin.

Foreign pension distributions can be fully or partly taxable in the United States, subject to the applicable treaty and individual facts. Local fund products should also be reviewed for U.S. classification before purchase.

• U.S. IRA and employer plans
• German statutory pension and occupational arrangements
• Private pension and insurance contracts
• U.S. and German brokerage accounts
• Employer stock and deferred compensation

Coordinate custody, currency, and the move year

Ask custodians whether accounts can remain open after the move and what trading or advice restrictions may apply. Model near-term euro spending separately from long-term portfolio exposure.

Finally, build a move-year calendar for bonuses, vesting, sales, pension contributions, property transactions, and charitable gifts. Timing should be reviewed by professionals in both countries before implementation.