Support for executors or trustees of U.S. estates in Germany

We advise and assist clients acting as executors or trustees of U.S. estates or trusts with assets in Germany and/or having German heirs. Our services include:

• advice on the recognition of a U.S. Will or trust in Germany;
• representation in proceedings to obtain a German certificate of inheritance or German certificate of executorship;
• communication with German financial institutions, e.g. banks, savings banks, credit unions or insurance companies; 
• advice on the tax liabilities of the executor or administrator in Germany;
• representation towards German Inheritance and Gift Tax Authorities;
• obtaining a tax clearance certficate (Unbedenklichkeitsbescheinigung) for the release of German assets; 
• defending against claims German forced heirship (Pflichtteil) / statutory share claims; 
• Consulting regarding the structuring and timing of distributions from U.S. trusts by U.S. trustees to German resident beneficiaries to minimize any German estate, inheritance and gift tax liabilities.

Representation throughout Germany

We represent clients in courts throughout Germany. In the case of representation in a probate court (responsible e.g. for certificate of inheritance proceedings), travelling to the probate court is generally not necessary, as correspondence in probate matters is usually exclusively electronic/postal and a personal appearance is almost never necessary.

Client communication

We generally communicate with our clients remotely, i.e. by telephone, e-mail and video telephony (Zoom, Teams). We offer personal counselling in Germany at our offices in Berlin, Hamburg (limited) and Munich (limited services)