Tax non-resident · USA · Canada

Financing property in Germany while living in the USA or Canada

Residence in the USA or Canada — no conversion right, but a very limited choice of banks. What you need to know, and why choosing the right bank is decisive.

Key figures

USA/Canada residence at a glance

✓ No Conversion right (not EU)
USD/CAD At specialist banks (15–25 % discount)
35–45 % Equity + incidental costs
5–10 % Of all banks for the USA

Why the USA and Canada are a special category

No conversion right — that is the advantage. But many German banks see a US residence as elevated risk: USD/EUR exchange-rate swings, FATCA reporting obligations, different legal systems. Some banks decline a US residence outright. I know the banks that assess it — and the ones that decline across the board.

FATCA note: US persons with foreign accounts may have particular reporting obligations. Please consult a tax adviser in both countries — that is independent of the financing.

Terms USA/Canada

  • Loan-to-value: 55–65 % standard, max. 70 % with very good creditworthiness
  • USD/CAD income: possible at 2–3 specialist banks, with a 15–25 % discount
  • Minimum loan: often €150,000–200,000 — for small amounts, US cases are not worthwhile for banks
  • Legal question: German banks usually require German law to govern the loan agreement — standard
  • Notary appointment: a power of attorney with apostille (US notary) or travelling in person to Germany
  • Equity transfer: US bank statements are accepted; the actual transfer to Germany is a standard banking process
The real obstacle

Not the distance — the reporting obligations

Most people assume distance is the problem. It is not: powers of attorney, video identification and remote completion are routine. What sets this case apart is the regulatory weight that a US connection brings with it.

German banks are obliged under intergovernmental agreements to identify and report accounts held by US persons. The term is broader than most expect — it covers US citizens regardless of where they live, and green card holders. For a proportion of lenders, the resulting compliance workload is the reason for the rejection, not the credit risk. That is frustrating, because it has nothing to do with your financial strength. It is also predictable — and avoidable, if you approach the right houses.

For Canada this mechanism does not bite in the same way. The case is usually simpler — but it remains a foreign-currency case.

Currency and source of funds

Two things to settle before you apply

  • USD/CAD and § 503 BGB. Living outside the eurozone means a euro loan gives you a statutory conversion right. Lenders unwilling to carry that obligation decline before they have looked at your income. The circle that will is small — but it exists.
  • Source of funds. Equity transferred from a US account must be documented without gaps: payslips, statements, and where relevant the proceeds of a property sale. This is the point at which approved financings stall shortly before completion — not because the money is problematic, but because the chain of evidence is incomplete. We assemble it before the application, not after.

One further point for those planning to return: do not choose too short a fixed-rate period. Otherwise the refinancing falls precisely into the window where your income is hardest to evidence — between resigning there and signing a contract here.

Request a feasibility check

I review your specific financing situation — free, non-binding, in German, English or Russian.

Common questions

Does it work for the self-employed in the USA?

Only to a very limited extent. Employees with regular USD income have considerably better chances. We assess your specific case.

How many properties may I own?

Ideally no more than one or two in your portfolio. With more, the choice of banks narrows further, but it is not necessarily impossible.

Can I modernise an existing property?

Modernisation measures can often be financed within the overall financing.

Does the enquiry trigger a SCHUFA check?

No. The first online enquiry only records key figures and does not trigger a SCHUFA entry.