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If you come to Germany with money in traditional 401k or IRA accounts, you may be able to convert money in these traditional accounts to Roth accounts without paying German or US taxes on the conversions. If you later move back to the US you could withdraw from the Roth accounts tax-free. It has been discussed on this forum that the count case "Urteil vom 9.8.2018, Az. 11 K 2738/14" and the rejection of the appeal at the BFH means that withdrawals of contributions from traditional 401k and IRA accounts are not taxable by Germany. Only once you start withdrawing more than you contributed the gains are taxable as capital income. I think this opens two possibilities for US citizens who still have to pay tax on their world-wide income to the IRS. 1)If they have mostly earned income and their income falls below the foreign-earned-income exclusion amount, they can use their standard deduction to offset roth conversions. This strategy is discussed on various websites online as it seems to apply to US-expats in several countries. 2) The US-German tax treaty may open up another possibility if they are paying presumably much higher German income taxes on their earned income from jobs or freelancing in Germany. US retirement accounts are treated as Pensions in articles 18 and 18A of the treaty. Pension income is taxable in the resident country. Of course, through the savings clause the US reserves the right to tax these Roth conversions for US citizens anyways. However, US citizens can also resource this income and use tax credits on it. The question is to which foreign tax credit category does this belong? I think until recently resourced income went into the "resourced by treaty" category where it is not of much use. However since about 2018 there is language in the form 1116 instructions that this category does not apply to US citizens who are residents of the foreign treaty countries. So is pension income general category or passive? The form 1116 instructions and US code don't explicitly define retirement account withdrawals or pension income belonging to any category. Since contributions are from wages/earned income I think at least the basis should be able to be classified as general category and the gains as passive. It is not clear to me if for US-purposes one can withdraw the general category part first or has to withdraw general/passive proportionally considering the ratio of contributions to gains in the account. Anyways, it seems possible that a substantial portion of the withdrawal could be put in the general category where one could use the foreign tax credits from earned income that tend to accumulate if one lives and works in Germany. Path 1 seems relatively well established to me. I am not sure about path 2. What do the tax experts think (@Straightpoop @PandaMunich)? Do any US retirees in Germany resource withdrawals from their US retirement plans and use foreign tax credits in the general or passive categories?  

From what I understand I could do contracting for some companies. However I see most jobs on USA jobs are for people not already on the German economy and I don’t know where else to look.