One family, two countries — one plan that works in both.
A US will or living trust alone often does not work the way you expect for assets in Germany. And German rules on forced heirship and inheritance tax can apply even if you have lived in the US for decades. We make sure your plan works on the German side, together with your US estate planning attorney.
Deutsch oder Englisch — ganz wie Sie möchten.
What your plan needs to cover
Which law applies?
Under the EU Succession Regulation, German courts generally apply the law of your last habitual residence — unless you choose the law of your nationality in your will.
Does your US will work for German assets?
A validly signed US will is usually recognized as to form. German courts and banks may still require a certificate of inheritance, translations and additional steps.
What about your living trust?
German law does not know the trust. German assets are often not effectively in the trust, and trust distributions can be taxed differently in Germany.
Forced heirship and inheritance tax
Children and spouses may have a compulsory share (Pflichtteil). German inheritance tax can apply if you or your heirs live in Germany, or to German real estate.
Lifetime gifts
German tax-free allowances renew every ten years — timing matters.
Your plan, checked from the German side
We review your existing documents, show you where they collide with German law, and draft what is missing — in coordination with your US attorney.
- Review of US wills and trusts for German assets
- German wills, estate contracts and choice of law
- Gift and inheritance tax planning for both countries
- Powers of attorney and advance directives that work in Germany
- Coordination with your US estate planning attorney and CPA
Frequently asked questions
Do I need a separate German will?
Not always. Sometimes one coordinated will is enough, sometimes a separate German will for German assets is the better choice. That depends on your assets and family.
Can I choose US law for my estate?
If you are a US citizen, you can choose the law of your nationality. For dual citizens, the choice needs particular care.
We are German and moved to the US. Does German law still apply?
Often not to the succession itself — but German inheritance tax can still apply for several years after you left Germany, and to German assets.
Do you work with our US estate planner?
Yes. We handle the German side and coordinate with your US attorney and CPA.
Watch: I explain it on video
In plain English, from me personally.
Plan once, for both countries.
In a free 15-minute call we tell you which German issues your plan needs to address.
Nicola S. Casper-Hoesl is admitted to practice law in Germany (Rechtsanwaltskammer München) and has been admitted in Colorado as a Foreign Legal Consultant since 2021. She advises on German law only. Nothing on this website is advice on U.S. federal or state law or U.S. tax matters; please coordinate those with your U.S. attorney or CPA.