About the Course
Introduction
This CLE/CPE webinar will provide tax counsel and planners with a comprehensive guide to tax planning challenges and opportunities for clients who have a tax presence in both the U.S. and Germany. The panel will discuss the U.S. tax law and treaty provisions that govern tax and fiduciary rules in both Germany and the United States. The webinar will focus on the U.S. tax and other consequences for German clients with a U.S. tax presence and U.S. taxpayers with Germany-based assets.
Description
The U.S. and Germany have significant economic and social ties, resulting in a constant flow of cross-border business transactions and citizens migrating between the two countries. Tax counsel and advisers must navigate challenges stemming from the interpretation and enforcement of U.S. and German tax rules to avoid adverse tax liability from either country.
Among the most critical planning challenges is reconciling the U.S. and Germany rules governing residence and domicile. U.S. and Germany domicile rules have some differences, and even inadvertent failure to meet filing obligations due to a misapplication of domicile rules can be costly. U.S. tax advisers serving clients with a presence in the U.S. and Germany will need to understand the domicile rules to avoid costly tax and penalties.
Another critical planning element is avoiding dual taxation on income and gains. The U.S. and Germany have a comprehensive tax treaty system that addresses most dual taxation concerns, but, as in all international planning, tax advisers must understand the particular provisions to avoid an unpleasant tax bill—or maybe two.
The interaction of these regimes—residency rules, treaty provisions, the saving clause, and relief mechanisms—creates both planning opportunities and compliance risks. Tax counsel must efficiently navigate these rules to minimize adverse tax liability from either country.
Listen as our experienced panel provides comprehensive and practical guidance on navigating U.S.-German cross-border tax planning and reporting issues.
Presented By
Mr. Carlson is a tax lawyer and CPA who primarily counsels buyers and sellers on M&A transactions with deep experience in the architecture, engineering and construction (A/E/C) sector and advises developers and investors on real estate transactions. His real estate work includes inbound investments by foreign investors into U.S. real estate, Section 1031 exchanges, qualified opportunity funds, carried interest structuring, and UBTI minimization for tax-exempt investors. Mr. Carlson's broader practice includes complex corporate and tax planning for domestic and international transactions, and foreign account and income disclosure and penalty abatement issues including the Streamlined Filing Compliance Procedures and Delinquent International Information Return Submission Procedures. He helps companies (domestic and international) and individuals structure corporations, LLCs, partnerships, and nonprofit entities to achieve their transactional tax and corporate planning goals, and successfully resolve tax controversies with the IRS and state taxing authorities.
Mr. Moore founded KJMLAW Partners in 1992 as a way of investing in his hometown community. The law firm specializes in the focused areas of estate planning, trusts and probate services with additional expertise in both domestic and international business transactions and tax planning and tax controversy representation for individuals and companies. Over the past two decades, Mr. Moore has built a reputation for repeated ‘wins’ in court on behalf of the firm’s clients. Today, KJMLAW Partners distinguishes itself from other firms of its stature by providing personalized attention to clients, particularly when it comes to financial matters.
Mr. Ruiz has over twenty years of experience specifically in international tax niche with a specialization in tax advisory, tax planning, structuring and compliance. He represents high-net-worth clients, manufacturing and distribution companies, public companies, real estate clients, and technology-based companies. Mr. Ruiz's area of expertise lies in helping companies and individuals with cross-border tax issues alongside providing advisory functions to help optimize tax profile of international business. He is a noted industry expert and has been a prolific speaker and author on topics pertaining to international taxation. Mr. Ruiz has participated by providing his valuable insights in articles like Bloomberg’s BNA tax management portfolios, foreign income-based transfer pricing on rules and practice in selected countries and more.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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CPE credit is not available on recordings.
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BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Date + Time
- event
Thursday, August 27, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. The U.S.-Germany income tax treaty overview and dual tax mitigation provisions
II. Domicile and residency rules
III. Passive and unearned income treatment
IV. U.S. tax reporting requirements for Germany-sourced investments
V. Dual tax relief mechanisms
VI. Totalization agreement
VII. Planning considerations
The panel will review these and other important topics:
- What are the tax treaty provisions for mitigating dual taxation on ownership of cross-border pass-through entities?
- Limitation of benefits clauses and provisions in the U.S.-Germany income tax treaty
- Key risks and challenges of passive/unearned income in cross-border situations
- U.S. reporting requirements for German-sourced investments
Learning Objectives
After completing this course, you will be able to:
- Recognize U.S. tax reporting requirements for U.S. taxpayers residing in Germany
- Establish the domicile of the taxpayer and whether tax treaty benefits are available based upon the determined domicile
- Distinguish among the various tests used to determine whether a taxpayer is eligible for tax treaty benefits
- Identify opportunities to mitigate dual taxation
- Identify the limitations of benefits in the U.S.-Germany tax treaty
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation, including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI/NCTI, Subpart F, and the related Section 250 deductions.
BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
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