Practical applications of the Germany-U.S. tax treaty

Resource Information

The work Practical applications of the Germany-U.S. tax treaty represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Practical applications of the Germany-U.S. tax treaty

Creator

• Ehlermann, C
• Maywald, A

Subject

• limited liability company
• tax treaty
• LoB
• withholding tax
• treaty shopping
• case law

Language

eng

Summary

This article looks at select German cases based on the 2006 Protocol to the Germany-U.S. tax treaty and relevant changes to the tax law and tax court decisions, and describes the German interpretation of some treaty provisions, including treatment of U.S. LLC income, eligibility for 0 percent withholding tax, German anti-treaty-shopping rule, LOB clause in the Germany-U.S. treaty, treaty withholding tax rates, and calculation of minimum holding period

Citation source

In: Tax notes international. - Falls Church. - Vol. 58 (2010),

Language note

English