The rules of the game just changed, and anyone living between the U.S. and Germany can feel the floor move. We unpack what actually shifted in 2026, why the headlines about a “1% transfer tax” missed the point, and how to build a defense that keeps more of what you earn. From business owners hit by NCTI to families blindsided by Germany’s new exit tax on ordinary funds, this conversation trades confusion for a clear plan.

We start by killing the remittance panic with the banked exemption—digital, KYC‑compliant transfers remain untouched—then pivot to the bigger story: GILTI’s transformation into NCTI and the death of QBAI. For entrepreneurs with German companies, Section 962 becomes a lifeline, converting punishing U.S. exposure into a liability that can be wiped out by German corporate taxes when the election is filed correctly. On the personal side, we walk through the “millionaire next door” trap where steady ETF saving pushes a household over Germany’s 500,000 euro acquisition threshold, triggering a deemed sale on departure and a brutal liquidity crunch. The fixes—portfolio washing and spousal allocation—only work before deregistration, so timing is everything.

Retirement isn’t spared. We explain how Germany now taxes full 401(k) distributions and treats Roth IRA growth as taxable, creating a foreign tax credit mismatch that can’t be papered over. Add the PFIC versus PRIIPs stalemate—penalties for European funds on the U.S. side and restricted access to U.S. ETFs on the EU side—and investing feels boxed in. We map three legal paths forward: options assignment to acquire U.S. ETFs, disciplined portfolios of individual stocks with improved German loss netting, and long‑horizon German real estate that becomes tax‑free after ten years. With the OBBBA locking the U.S. estate tax exemption at $15 million per person, most families can focus their estate planning energy on Germany’s lower allowances.

The playbook is simple, not easy: stay banked, file the 962 election, manage acquisition cost before you move, and split assets into three buckets across jurisdictions. Subscribe for more deep, practical breakdowns of cross‑border money problems, and share this episode with a friend who needs a plan before 2026 turns their savings into a tax surprise.

More info at Investing from Germany - Financial planning for US citizens moving to or living in Germany in 2026. If you have questions, contact us.

Moving, Working, and Investing for Americans Abroad