Description
A guide for estate planners, CPAs, and attorneys whose client is the heir, in the United States or in Germany, of a U.S. citizen who was domiciled in Germany at death: why citizenship keeps the estate on Form 706 and the treaty makes Germany the first taxing country, the German inheritance tax on both heirs and the succession law the decedent could choose, the release of the frozen U.S. account without a transfer certificate, the U.S.-person heir’s step-up and carryover PFIC taint, the German heir’s position under the income tax treaty, and the sequence of administration and division.
15 pages. Updated in September 2026.