Over the past week, our free seminar series — Your Family. Your Estate. — German Inheritance Law — took to the road, with sessions first in Hamburg and then in Berlin. Both evenings brought together U.S. citizens and cross-border families living in Germany, and both left me grateful for the trust and curiosity in the room.
What struck me most was not the turnout, though it was wonderful, but the quality of the questions. These were not abstract legal puzzles. They were the real concerns of people building a life across two countries: parents wondering who would care for their children, spouses assuming an inheritance would pass automatically, families holding property on both sides of the Atlantic and unsure which country’s rules would govern it.
The questions that come up again and again
Every audience is different, yet certain themes surface in every city. In Hamburg and Berlin alike, the conversations returned to a handful of issues that American families in Germany most often discover too late.
The first is the question of who actually inherits. Many people arrive assuming their spouse will automatically receive everything. Under German law, that is frequently not the case — the statutory rules of the German Civil Code (BGB) divide an estate in ways that can surprise families accustomed to U.S. norms.
The second is the reach of the EU Succession Regulation, often known as Brussels IV. Since 2015, it has fundamentally shaped which country’s law applies to a cross-border estate, and it offers planning opportunities that many families do not realize are available to them.
The third is one of the most practical, and the most urgent: a U.S. medical directive or power of attorney will generally not be honored in a German hospital. Families who believe they are protected often are not, precisely at the moment protection matters most.
And finally, there is the U.S.–Germany double-tax question — the risk that an estate is taxed on both sides, and the planning that can prevent it.
Why these evenings matter
Cross-border estate planning is easy to postpone. It rarely feels urgent until it suddenly is. The purpose of these seminars is not to alarm anyone, but to make the invisible visible: to show families where the gaps between two legal systems actually lie, and to give them the confidence to close those gaps in good time.
The engagement in Hamburg and Berlin confirmed how much need there is for clear, practical guidance in this space. To everyone who joined us in both cities — thank you for your questions, your openness, and the conversations that carried on well after each session ended.
What comes next
The series continues, and the next session moves online.
Online seminar — 27 August 2026. If you would like to revisit these topics, or know someone who could not attend in person, this is an easy way to take part from anywhere. Register here and we would be grateful if you would help spread the word.
Every family’s situation is unique, and some questions are best explored individually. If you would like to talk through your own circumstances, you are welcome to book a free 20-minute consultation directly through this website.
