There's no exit tax, though. Every asset I own was paid for with money I already paid taxes on. Though I did have a Jewish grandparent or two, they can't grab what I have just because they feel like it--that really did end in 1945, and that was here in Germany.
If I'm paying 52% here or 39% back home, I can still survive on what's left (as long as this 98% nonsense gets straightened out).
The one thing I'm worried about is my Roth IRA. I did the conversion when my residence was still in the USA, which means if I want to retire and live off that, I owe nothing further on it since I paid the taxes up front upon conversion. The Germans have never heard of the Roth conversion.
A friend is a judge on the German tax court, and he wrote his doctorate on double taxation. He had never heard of a Roth IRA conversion, and said as far as he knows there has never been anything written into the double taxation agreement about it. He said the Germans might want to tax me on it, or at least the gains in its value since the conversion. This would be completely contrary to the US law that covered me when I did the conversion. As that would eat away either a quarter (if they tax only the gain) or half (if they want to tax all of it) of what I have saved for retirement, I will give up my German residence before I let them confiscate that. I paid my taxes on that--let them go attack Washington if they want to confiscate what's left.
Apparently there has never been a test case of an American having moved to Germany after having his IRA converted to a Roth IRA, so at the moment, there is no legal precedent to fall back on.
Plus, I have no intention of giving up my US citizenship. It's where I was born and grew up. It's what I am, and I see no reason to choose to be something else. I am in Germany by choice, not by necessity. My wife has a pretty strong hold on me, it's true. Her country does not. If she moves to the States with me some day, she has no intention of becoming an American citizen. It's not who she is. I work in Europe. I could work in the States, too. My wife retired a few years ago. I figure I'll still be working another 15 years or so (I'm 63 now).
My dad retired at 78, but only because pancreatic cancer squeezed the life out of him. His farewell column (he was a journalist) appeared in his newspaper 8 days before he died. I'm not a journalist, but I suspect that's how I'll go out, too.
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