US-American-German international estate

The winding-up of an international estate with connections to Germany and to the US is very challenging. Dr. Hosser’s over 17 years of experience with the winding-up of an estate for US-American customers are extremely helpful to achieve very good results in a timely manner for our customers from the US.

Having said that, we are – of course – aware of the fact that there is no uniform US-American inheritance law, because each US Federal State has its own inheritance laws. One of the difficulties which a German-US-American settling of an estate has is, that the German and European legal system are very different from the common-law-rules in Anglo-American countries like the U.S., especially as it comes to probate procedures after a case of death.
The civil law-system of Germany and its inheritance law as well as its procedural laws for probate procedures make it very difficult if not almost impossible for customers from the U.S. to settle an estate in Germany independently and without any professional assistance. The language barrier – the German probate courts in all regularity correspond exclusively in German – is not the largest obstacle in that context, but the large differences between probate procedures in Germany and in the US are.
Dr. Marcus A. Hosser in Kanzlei - probate law germany - Flaggen-USA und BRD

A very important preliminary question which we can assess for you is, which substantial inheritance law is applicable pursuant to the relevant rules of the EU Succession Regulation. Dr. Hosser is an expert for private international inheritance law and has – during his over 17 years of experience with international succession cases – dealt with many international estates with connections to Germany and the US. We are also experienced with starting and leading probate procedures for our clients. Even when we have not yet dealt with a case of succession with connections to a certain US Federal State, this is no obstacle for our legal assistance with the winding-up of the German estate. German probate and inheritance laws are the laws we are familiar with and thus, we can explain those rules to any US-American customer, regardless of whether he or she resides in NY, Florida, California or in Kansas, in a way that allows the client a decision about the next steps to be taken on the US-customer’s behalf.

Summing it up, we cannot recommend any prospective customer from the U.S. to take a try with settling of an estate in Germany without any professional assistance. In many calls or emails, which reach us, the persons who had tried that out, reported about very frustrating experiences, either with German courts or with other third parties with connections to the German estate like banks or – last but not least – the German inheritance tax office. As a specialist tax lawyer, Dr. Hosser can assist with German inheritance taxes as well as with German gift taxes, also in international constellations, each.

If you have the task to settle an estate with connections to Germany or even only a single asset in Germany like a bank account or a securities deposit account, our well-meant advice is to get in touch with our law office and to make the investment in our professional assistance with the winding-up of the estate in Germany. We are looking forward to receiving your message over our contact form, your email or – as an alternative – your call to our office.

DR. HOSSER Rechtsanwalt

Bismarckstrasse 61 D-76133 Karlsruhe Germany

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