Do I need to file in both countries every year?

If you are a US person (citizen or green-card holder), the IRS requires a 1040 every year regardless of where you live. Whether you also need to file in Germany depends on whether you are a German tax resident (unbeschränkt steuerpflichtig) or have German-source income that triggers limited liability (beschränkte Steuerpflicht). Most US-resident German citizens with no German income do not file in Germany annually. Once they have German rental income, German pension distributions, or significant German investments, they typically do.

What is the difference between FBAR and Form 8938?

Both report foreign financial accounts to the US government, but they go to different agencies and have different thresholds. FBAR (FinCEN 114) goes to the Treasury Department and is triggered when the aggregate value of foreign accounts exceeds $10,000 at any point during the year. Form 8938 goes to the IRS as part of your tax return and has higher thresholds — $50,000 / $100,000 for single filers depending on whether you are domestically or internationally located, doubled for joint filers. You may need to file one, both, or neither depending on your specific account values and residency.

Are German Investmentfonds really treated as PFICs?

Almost always, yes. Any non-US-domiciled pooled investment fund — most German Investmentfonds, including UCITS funds sold through Comdirect, ING DiBa, ConsorsBank, etc. — falls under PFIC (Passive Foreign Investment Company) rules under US tax law. Default PFIC treatment is punitive: ordinary-income tax on gains plus interest charges, with no benefit from long-term capital gains rates. The two opt-out elections are QEF (Qualified Electing Fund — requires the fund to provide annual statements that almost no German fund does) and mark-to-market (taxes unrealized gains annually as ordinary income). Most US-resident Germans hold these funds despite the tax cost; some sell and switch to US-domiciled ETFs to escape the rules.

Can I represent myself for a simple return and skip the advisor?

For a US-resident German citizen with one German bank account under $20,000 and no other German income, yes — TurboTax with the FBAR add-on or H&R Block Expat Tax Services can handle it. The line where DIY stops being safe is when treaty positions become relevant (Form 8833), when PFICs are in play, when there is German pension activity, or when an audit risk emerges. The IRS penalty for a willful FBAR violation starts at $10,000 per account per year — not a place to economize.

My German tax advisor in Germany says I do not need a US advisor — should I trust that?

No. A Steuerberater registered only in Germany is not licensed to practice US tax law and almost certainly is not current on FBAR, FATCA, PFIC, or US treaty enforcement practice. Their knowledge stops at the German border by design. The reverse is also true — a US CPA is not qualified to advise on German tax obligations. You need either a dual-licensed advisor or two coordinated advisors, one each side. Anyone telling you "one is enough" is operating outside their competence.

How to Find a German Tax Advisor in the USA

When you need a cross-border tax advisor (and when you don't)

If you are a US citizen or green-card holder with no German income, no German bank or brokerage accounts, no German real estate, and no German pension claims, a regular US CPA is fine. The moment any of those exist, you have a cross-border situation. The clearest triggers are: any German bank or brokerage account exceeding $10,000 in aggregate at any point in the year (FBAR / FinCEN 114 reporting), any specified foreign financial assets above the IRS Form 8938 thresholds, German rental income (must be reported on Anlage V in Germany and Schedule E in the US, with foreign tax credit reconciliation), German pension contributions or distributions (Riester-Rente, Rürup-Rente, betriebliche Altersversorgung — each treated differently by the US-Germany treaty), and any inheritance or gift from a German person above the federal estate-tax exclusion threshold.

What "dual-qualified" actually means

Tax advisors marketing themselves as cross-border experts fall into three tiers. The strongest are dual-licensed: licensed as a US CPA (or Enrolled Agent) AND as a deutscher Steuerberater registered with a Steuerberaterkammer. They can sign filings on both sides and have professional liability coverage in both jurisdictions. The second tier is single-licensed but specialized: a US CPA who has built deep practice expertise in German cross-border issues and partners with a German Steuerberater for the German filings. Many of the best advisors fall here. The weakest tier is generalist CPAs who claim cross-border capability based on having a few German clients — they will get you through standard FBARs but lack the depth for treaty disputes, exit-tax planning, or pension structuring. Ask directly: "Are you licensed as a Steuerberater in Germany?" If no, "Do you partner with a Steuerberater for German filings?" If still no, keep looking.

Specific filings a US-Germany advisor must handle in their sleep

On the US side: Form 1040 with Schedule B for foreign accounts, Form 8938 (FATCA — Statement of Specified Foreign Financial Assets), FBAR / FinCEN 114 (the standalone foreign account report — different threshold than 8938), Form 8833 (treaty-based return position disclosures), Form 1116 (Foreign Tax Credit), Form 3520 / 3520-A (foreign trusts and gifts above the threshold), Form 8621 if you hold any non-US mutual funds (PFIC reporting — punitive default treatment unless QEF or mark-to-market election made on time). On the German side: Anlage AUS for foreign income, Anlage KAP-INV for foreign capital income, NVA Bescheinigung for treaty-based withholding adjustments, exit-tax (Wegzugsbesteuerung) calculations under §6 AStG if you hold significant participations and are giving up German tax residency.

How much you should expect to pay

Cross-border returns cost more than domestic-only returns because the work is genuinely more complex and the liability exposure is higher. In 2026 USD, expect roughly: simple expat return with one or two foreign accounts, $800–$1,500 per year. Moderately complex (foreign rental income, foreign pension, multiple accounts, treaty positions): $1,800–$3,500. Complex (PFICs, trust reporting, exit-tax planning, dual-resident year, business income): $4,000–$8,000+. Hourly rates range from $250 to $600 depending on city and seniority. Boston/NYC/SF tend to be higher than Atlanta/Houston/Miami. Most cross-border firms quote a fixed annual fee after a paid intake call (usually $250–$500 for the intake itself, often credited against the engagement). Ask for the fee structure in writing before signing.

Five questions to ask in the first call

1) "Are you licensed as a deutscher Steuerberater, or do you partner with one?" — Names matter; ask for the firm name and Kammer registration. 2) "How many of your clients have my profile?" (e.g., German citizen with US W-2 income and a German rental property). Specificity beats generality. 3) "Have you handled exit-tax (Wegzugsbesteuerung) planning?" — only relevant if you might leave the US and re-establish German residency, but a good advisor will recognize the question instantly. 4) "What is your approach to PFIC reporting for German Investmentfonds?" — anyone who answers "we just do mark-to-market" without explaining trade-offs is too superficial. 5) "Who actually does the work — you, an associate, or an offshore team?" — important for complex returns where errors are easy and consequences are six-figure penalties.

Using this directory to shortlist

Browse the Accounting & Tax category for German-affiliated tax advisors across the US. Filter by your city or state to find ones near you. Listings marked with a German connection have either a German owner / Steuerberater partnership or are US subsidiaries of German firms. We do not rank or rate advisors — that is for you to evaluate. We do verify the German connection and the basic legitimacy of the practice before approving a listing. Always do your own due diligence: check the US state CPA license at your state's Board of Accountancy, check the Steuerberater registration at the relevant Kammer (e.g., Steuerberaterkammer Berlin), and ask for client references in your specific situation type.