Buying a US Home from Germany: Mortgage, Visa and Tax Facts

Q: Does my SCHUFA record help me get a US mortgage?

It does not create a US credit score, because US scores only reflect what US lenders report. SCHUFA provides a free copy of your data on request, and it can sit in your file as evidence of how you have managed credit. Whether a lender considers it is that lender's choice, so ask at the start.

Q: Will I pay German tax if I sell my home to fund the move?

Under section 23 of the Income Tax Act a sale of real estate is taxable if no more than ten years lie between purchase and sale. A home you used only for your own living purposes, or used yourself in the year of sale and the two years before, is excluded. If you let the home before selling, check the position with a Steuerberater first.

Q: Who replaces the Notar in a US purchase?

No single person. A settlement agent, which is a title company, an escrow company or an attorney depending on the state, handles the money and has the deed recorded. A title search and title insurance cover the checks a German notary and the Grundbuch provide. You can hire your own attorney, and in some states that is customary.

Q: I own part of a GmbH. Does moving to the US trigger tax?

It can. Under section 6 of the Foreign Tax Act, giving up German residence is treated as a sale of shares in a corporation in which you held at least 1% within the last five years. This is one of the costliest surprises for entrepreneurs who emigrate, so take advice before you deregister, not after.

Germany and the United States at a glance

Figures last checked: 3 October 2026

Visiting: In the Visa Waiver Program since 1989: viewing trips need an ESTA, not a visa.
Treaty visas: E-1 trader and E-2 investor status available, under the treaty in force since 14 July 1956.
Income tax treaty: Yes, in force.
Estate tax treaty: Yes, covering both estate and gift tax.
Social security agreement: Yes, since 1 December 1979.
Currency: Euro, so the down payment carries exchange-rate risk against the dollar.
Already there: About 519,000 people born in Germany live in the United States (Census Bureau, 2024).

Your route into the United States

German citizens can visit under the Visa Waiver Program, which covers viewing trips and nothing more. For a US mortgage on standard terms the lender has to establish that you live in the country lawfully. That makes your status the first item to settle: a green card, an employer-sponsored visa, or for business owners the E-1 or E-2 category, open to Germans under the 1956 treaty. An E-2 is an investment in an operating business. A house does not count.

Buying a holiday home while you remain resident in Germany is possible, but usually through a foreign national loan with a larger down payment and a higher rate. The guide to visa status and US loans sets out the options.

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What a US lender sees of your German finances

Your SCHUFA history stays in Germany. On arrival you have no US credit score, and you build one from your first US bank account and card. Request your free SCHUFA data copy before you leave: it costs nothing and gives a lender something to read, even though it cannot be scored.

German salaries and savings need translating in both senses. Fannie Mae's rules ask for two years of US federal tax returns before income from a foreign employer paid in foreign currency can be counted, and require assets abroad to be converted into dollars and held in a US-regulated institution before closing. Expect the lender to focus on your US employment contract and on funds already in a US account.

A faster and looser process than you know

In Germany the notary drafts the contract, reads it aloud, secures your position with a priority notice in the land register and only then tells you to pay. If you buy from a business you must have the draft for two weeks first. The system is slow and it protects you without your having to ask.

A US purchase puts the burden on the contract you sign. Protection comes from the contingencies you negotiate, such as financing, appraisal and inspection, and the whole transaction usually completes 30 to 45 days after the offer is accepted. Our comparison of the US timeline with Europe walks through each step.

Your German home and your shares

If the sale of your home is funding the down payment, check the ten-year rule in section 23 of the Income Tax Act. A home used only for your own living purposes is excluded, as is one you lived in during the year of sale and the two years before. A period of letting before the sale can change that.

If you keep the property and let it, or buy in the US while staying resident in Germany, rental income from property abroad counts as foreign income in your German return, and the tax treaty decides how double taxation is removed. For shareholders the larger issue is exit taxation: ending German residence is treated as a sale of any holding of at least 1% in a corporation held in the last five years.

Estate and gift tax

For people who are neither US citizens nor US residents, an estate tax return is due once US assets, including a house, exceed $60,000. Germany is one of only four EU countries whose treaty with the United States covers both estate and gift tax. How you hold a US home, and in whose name, is worth settling with a specialist before the purchase.

Checklist for German buyers

Confirm your US immigration status and when it starts.
Request your free SCHUFA data copy and gather payslips, tax assessments and bank statements.
Have the key documents translated into English.
Check the ten-year rule before you sell or let your German home.
If you hold 1% or more of a corporation, take advice on exit taxation before deregistering.
Open a US account, move the down payment early and plan the currency conversion.
Keep the financing and inspection contingencies in your US contract.

Questions people moving from Europe ask

Does my SCHUFA record help me get a US mortgage?

Will I pay German tax if I sell my home to fund the move?

Who replaces the Notar in a US purchase?

I own part of a GmbH. Does moving to the US trigger tax?

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Sources (11)

Figures and rules on this page were checked against these sources on 3 October 2026. Rates, prices and local rules change, so confirm anything you rely on before you commit.

Made, reviewed and approved by Bas Terpstra, AFM- and PGN-certified
Basterpstra B.V., Drachten, the Netherlands (AFM 12050993)

Who made this guide. Bas Terpstra makes, reviews and approves every guide, using AI tools and public sources as a starting point. Rules and figures change, so treat this as general information and confirm the details for your own situation.

This page is general information, not personal financial, legal, tax or immigration advice. Nothing here is an offer, and no rate, loan amount, approval or visa outcome is promised. Mortgage availability is subject to immigration status, income, credit, appraisal and lender criteria, and lending, tax and local rules change. Consult a licensed US lender, an immigration attorney and a cross-border tax adviser. Any property securing a loan may be at risk if payments are not made.