🎙️ I had the pleasure of being a guest on the Verdict Signal podcast last week, in an episode titled „Inheriting Debt“ — and the title gets at exactly the issue most U.S. clients don’t see coming.
Under U.S. law, when someone dies the estate is settled and creditors are paid out of estate assets before anything reaches the heirs. Under German law, it works the other way around: the heir steps into the deceased’s entire legal position at the moment of death — assets and liabilities. If your German aunt left €200,000 in property and €300,000 in debts, you’ve just inherited a €100,000 problem.
There is a way out — renouncing your inheritance — but the window is short: six weeks from the moment you know you’ve been named as an heir, or six months if you live abroad or the deceased had their last residence abroad. Miss it and the inheritance is yours, debts included.
This is one of the most common — and most expensive — surprises for U.S. citizens with family or assets in Germany. We covered this and a lot more on the episode:
If you have inherited or expect to inherit anything in Germany, this is worth 30 minutes.
#GermanInheritanceLaw #CrossBorderEstates #USExpats #Erbrecht #EstatePlanning #ProbateLaw
