German Inheritance Law

08/28/2026

Yesterday evening I ran a webinar for American and German-American families with property, heirs or children in both countries — an hour on what actually happens to an estate that sits in two legal systems. 30 of you came, and many stayed long past the end to ask questions. Thank you. It was one of the best evenings I have had doing this work.

Here is the moment it went quiet.

A widow inherits €600,000 from her husband. Passing to her directly, she is in German tax class I: €500,000 tax-free — in my example, about €11,000 in German inheritance tax.

The same €600,000, from the same husband, arriving through a US trust: German law has no trust of its own, so the payout can be treated as coming from a foreign entity — tax class III. Only €20,000 tax-free, rates from 30%. In the same example, about €174,000.

Nobody did anything wrong. The trust was good US planning. It just never met German tax law.

That is really the whole point of cross-border planning: not two good plans, but one plan that works in both countries.

If you missed it: we are doing it again in December. I am keeping a list so nobody has to find out about it by accident in a feed. Message this page, or email [email protected] with the word LIST, and you are on it.

And if you know an American family with something in Germany who should have been in that room: please send this to them. That is honestly how most people find me.

General information for education — not individual legal or tax advice.

08/24/2026

3 days to go — don't miss it. 🇩🇪🇺🇸

On Thursday, 27 August, I'm running my free webinar for American families with German ties: what happens to your estate when your life spans two legal systems.

🗓️ Thursday, 27 August 2026
🕕 18:00–19:00 Berlin · 12:00 pm ET · 9:00 am PT
💻 In English, on Microsoft Teams — free, registration required

Register here: https://www.eventbrite.com/e/your-family-your-estate-german-inheritance-law-for-us-citizens-free-webinar-tickets-1989798732573

General information, not legal advice. Bring your questions.

Know someone with a house, an account, or family in Germany? Tag them or pass this on — Thursday comes fast.

Free webinar (in English) on wills, guardianship, medical directives & US–Germany inheritance tax for Americans with German ties.

08/14/2026

She picked out the sunglasses herself. She wears them in the car, indoors, and — twice now — in the bath.

I take a lot of photos like this one. And every so often one of them stops me, because I do this for a living and I still catch myself avoiding the question underneath it:

If I weren’t here tomorrow, who would raise her?

I write that document for other families. I know the paragraph number by heart. And I still found it easier to draft it for a client on a Tuesday morning than to sit down at my own kitchen table and write the name down.

Here is the part that makes it harder for families like mine, with one foot in Germany and one in Colorado: it is not enough to write it once.

Which country’s court decides is driven by where your child actually lives — not by the passport in the drawer. And because the US never ratified the 1996 Hague Convention on the protection of children, a German document does not automatically travel to an American court, and an American one does not travel to Germany. Most cross-border families need one on each side, naming the same people.

If you have been meaning to do this for months: I understand completely. I was you. It is one uncomfortable afternoon, and then it is done, and you get to stop carrying it around.

08/14/2026

This is my daughter. She picked out the sunglasses herself. They are non-negotiable and, as far as she is concerned, weather-independent.

I am a German attorney based in the US. I spend my working days on German estates — probate courts, Erbschein applications, inheritance tax files. And of everything I draft, the one document I put off longest in my own life was the one that decides who would raise this child if I weren't here.

Not because it is complicated. Because 🇺🇸🇩🇪
For families living between Germany and the US, there is a second layer, and it is the part almost nobody knows about. Which country's court would decide is generally determined by where the child habitually lives — not by which passport they hold, and not by where the document was signed. And because the United States never ratified the 1996 Hague Convention on the protection of children, a German appointment is not automatically recognised by a US court, and the reverse is just as true.

So the honest answer for most German-American families is: you need a document on each side, and they need to name the same people.

There is also a formal trap on the German side that catches nearly everyone. A guardian nomination only counts if it is written the way a will is written — entirely by hand and signed, or before a notary. A typed and signed page, however carefully drafted, is void. I have had to tell people that after the fact, and it is a terrible conversation.

If you have been meaning to sort this out for a while, this is your nudge. It is one afternoon. And it is the softest, most important thing you will ever put in writing.

Know a German-American family with small children? Send this along, or tag them.

08/11/2026

A little story, and then an invitation.

Earlier this summer I held in-person seminars in Berlin and Hamburg on German inheritance law, for families with one foot in Germany and one in the US. Both times, the most useful part wasn't my talk — it was the half hour afterwards, when people finally asked the questions they'd been carrying around for months. What do we do with the apartment? Why does the bank in Germany keep asking for an Erbschein (the German certificate of inheritance)? Does my American will cover anything over there?

And nearly everyone said the same thing: my family back in the States needed to hear this.

So, on popular demand, we're doing it again — online, and free.

Your Family. Your Estate. — German Inheritance Law for US Citizens
Thursday, August 27, 2026
6:00–7:00 pm German time · 12:00 pm ET · 9:00 am PT
In English, via Microsoft Teams. Free, RSVP required.

One hour on German succession law and wills, cross-border estate planning under the EU Succession Regulation, guardianship for your children, medical directives and powers of attorney, and inheritance tax across the Atlantic. No legal background needed, and all questions are welcome. This is general information, not legal advice for your particular situation.

Register here: https://www.eventbrite.com/e/your-family-your-estate-german-inheritance-law-for-us-citizens-free-webinar-tickets-1989798732573

Know someone with family property or a bank account in Germany? Tag them below or send this along — it's the kind of thing people wish they'd known a year earlier.

Free webinar (in English) on wills, guardianship, medical directives & US–Germany inheritance tax for Americans with German ties.

07/25/2026

Wheels down, back in Denver. ✈️

A few weeks ago this wing was carrying me toward Europe. Today it carried me home — and I'm still a little full from everything the trip held.

The highlights were my speaking engagements in Hamburg and Berlin. Standing in front of fellow Americans and Germans to talk through German inheritance law, and the very real questions that come up when an estate straddles Germany and the United States, is the part of this work I love most. The conversations after each session are always the best part — every family's situation is a little different, and every question sharpens how I think about the next case.

There was time to breathe, too: a short family holiday in Sicily that was every bit as wonderful as the work was rewarding. Sunshine, good food, and the people who matter most — the perfect counterweight to a busy stretch of travel.

And now — back to my desk, back to the everyday routine. Inbox open, files out, coffee getting cold while I read. Honestly? It feels good. The travel was a success, and the ordinary rhythm of the work is where the real progress happens.

To everyone I met in Hamburg and Berlin — thank you. To everyone wrestling with an inheritance that touches both sides of the Atlantic — I'm back at my desk, and happy to help.

07/18/2026

Thank you, Hamburg and Berlin. 🙏

Over the past week, our free seminar series — Your Family. Your Estate. — German Inheritance Law — brought together U.S. citizens and cross-border families in two wonderful rooms: first in Hamburg, then in Berlin.

The turnout, the questions, and the conversations that carried on long after each session confirmed what we hear again and again: American families living in Germany face real, often invisible risks in how their estates are handled across two legal systems.

Together we worked through the questions that matter most.

To everyone who joined us in Hamburg and Berlin: thank you for your trust, your questions, and your engagement.

The series isn't over. The next event will be an online event on August 27th — if you or someone you know abroad would benefit, we'd be grateful if you'd pass this along. Feel free to sign up here: https://www.eventbrite.com/e/1989798732573?aff=oddtdtcreator

07/13/2026

We've arrived in Hamburg — and Wednesday can't come soon enough.

My family and I touched down this weekend, and it's a joy to be back along the Elbe before a busy week ahead.

This Wednesday, 15 July, I'm holding the first session of my free seminar series — Your Family. Your Estate. — German Inheritance Law — created for U.S. citizens and cross-border families living in Germany.

We'll cover the questions American families in Germany most often discover too late:

- Who actually inherits under German law — and why it may not be your spouse
- How the EU Succession Regulation (Brussels IV) reshapes your estate plan
- Guardianship for your children if the worst should happen
- Why a U.S. medical directive and power of attorney won't work in a German hospital
- The U.S.–Germany double-tax trap

**Hamburg — Wednesday, 15 July 2026, 18:30**
betahaus Schanze, Eifflerstraße 43
Free admission · In English · RSVP required

If you — or someone you know in Hamburg — fits this description, please come and share.

Looking forward to seeing you Wednesday!

07/06/2026

One Week To Go!

07/06/2026

⏰ One week to go — free seminar for Americans in Germany

Your US will stops at the German border. 🇺🇸➡️🇩🇪

If you're an American living in Germany — or a family with assets or ties on both sides of the Atlantic — your US will, trust, or estate plan may not do what you think once German law applies. The result can be unexpected heirs, blocked bank accounts, and a probate process your family never planned for.

Join me for a free, plain-English evening seminar:

📌 What every American in Germany needs to know about inheritance, estate planning & protecting your children.

🗓️ Hamburg — Wed, 15 July 2026, 18:30
📍 betahaus Schanze · Eifflerstraße 43 · 22769 Hamburg

🗓️ Berlin — Thu, 16 July 2026, 18:30
📍 TuesdayCoworking · Bundesallee 187 · 10717 Berlin

We'll cover: why German law can override your US will, how the "forced share" can hand part of your estate to relatives you didn't choose, what happens to your children and your home, and the practical steps to protect your family — with real case examples.

✅ Free · ☕ Come with questions · 🎟️ RSVP required (limited seats)

Presented by Nicola Casper-Hoesl, German-qualified attorney for cross-border inheritance law.

👉 Reserve your seat: germaninheritancelaw.us