Determining Fiscal Domicile Under Article 4 of the Germany–U.S. Double Taxation Treaty: Dual Residences, Cross-Border Estates, and the “Center of Vital Interests”

For individuals who split their time between Germany and the United States, one of the most consequential legal and tax questions is often deceptively simple: Where is the individual actually tax resident? This issue becomes particularly complex where a person: owns residences in both Germany and the United States, spends substantial time in both countries, … Continue reading Determining Fiscal Domicile Under Article 4 of the Germany–U.S. Double Taxation Treaty: Dual Residences, Cross-Border Estates, and the “Center of Vital Interests”