Does Germany or the US tax my salary first on assignment?
For employment income the country where the work is physically performed normally has the first claim, so a German assignment salary is generally taxed there first and the US return is computed afterwards with relief for the German tax properly paid. Rates are rarely where the difficulty lies in this corridor. The difficulty is the items that do not belong neatly to one year or one country, such as equity awards straddling a move and pension arrangements whose treatment has to be established rather than assumed, and those decide the final figure.
How are my stock options split between Germany and the US?
Equity granted in one country and vested in the other is split by workdays. The award is treated as earned over the period between grant and vesting, and the earnings are apportioned according to where the work was physically done during that period, so an award granted before a move and vested after it belongs partly to each country. That makes a workday record covering the whole vesting period, not just the year of vesting, the document the position depends on. Reconstructing it years later from calendars and travel bookings is the expensive way to do this.
My equity vested after I moved to Germany, who taxes it?
Both countries are likely to have a claim, in proportions set by where you worked over the vesting period rather than by where you were living on the vesting date. Payroll in each country will often report the whole amount, because each system sees only its own side, and the two reports then overlap. The work is to compute the workday split once, use it in both returns, and claim relief on the correct side for the tax the other country was entitled to take first. Two full inclusions with no allocation is the usual position we are asked to unwind.
Is my German company pension taxable in the US as it builds up?
It has to be characterised before that can be answered. Pension arrangements in this corridor need characterising under the specific treaty articles dealing with them, on the arrangement's actual terms, rather than by analogy to a US plan. The characterisation decides whether employer contributions and internal growth stay outside the US computation until benefits are drawn, or enter it as they arise. Reach the conclusion once, write down the reasoning, and file consistently on it. A treatment that changes between preparers is what produces correspondence years later.
Do I get US relief for German wage tax withheld by my employer?
Relief is generally available for foreign tax properly paid on income Germany was entitled to tax first, but the claim rests on tax finally determined, not on the amount withheld through the payroll. German withholding and the eventual German assessment often differ, and an assignment package carrying equity and pension elements is exactly where they differ most. So the sequence is to complete the German position, take the assessed figure, match it to the right US year, and claim relief on that. A payslip total is a provisional number.
I am a researcher on a German university contract, who taxes my pay?
Start with where the work is done and what the payment actually is, then check whether a specific treaty provision applies to that class of payment, because the treaty deals with several categories individually rather than leaving everything to the general employment rule. A stipend, a salaried research post and a grant paid to an institution are not the same thing for this purpose, and the contract wording matters more than the job title. Academic moves in this corridor are also often long enough for pension and equity questions to arise alongside the pay.
How do families with assets in two countries handle inheritance?
With paperwork built for both systems rather than one. In practice that means wills that work where each asset actually sits, an executor with authority a foreign bank or land registry will accept, clearance certificates before the estate distributes so the executor is not left personally exposed, and an estate tax exposure calculation done while the person is alive and can still act on it. Doing it afterwards costs more and forecloses most of the options. See cross-border wills and trusts.
Do American citizens living abroad have to pay taxes?
American expats and green card holders need to file US returns for life, and many of them pay little or no US tax once the relief is applied — but the filing is what unlocks the relief, so the two questions have different answers. The exclusion for foreign earned income, the credit for foreign tax already paid and the treaty between the two countries between them usually leave the total at roughly the higher of the two countries' tax rather than the sum. Skip the return and none of it applies. See Americans abroad.
