Moving to Germany with a U.S. Trust: How German Law Treats the Revocable Living Trust, the Irrevocable Trust, and the Trust Interest of an American Who Becomes a German Resident

Description

A guide for U.S. estate planners, trustees, and CPAs whose client is moving to Germany with an existing U.S. trust: why the revocable living trust is transparent to German law during life and becomes a taxable acquirer at death, how § 15 AStG attributes an irrevocable trust’s income to a German-resident settlor or beneficiary under the Bundesfinanzhof’s current reading and the Ministry of Finance’s pending rewrite, and the review the plan needs before the move, not after it.
15 pages. Updated in September 2026.