New judgment on tax treaty between Germany and the US
By EsqSocial Corporation 15/07/14
Hybrid US S-Corporation eligible for participation exemption. Refund practice of taxes withheld remains to be seen. In a recent judgment (file no. I R 48/12), the German Federal Fiscal Court has commented on Art. 1 para. 7 of the new tax treaty...
By: Latham & Watkins LLP