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German Lower Court

|Treaty Development|Germany-United States
Germany-United States

revises "look through" approach to US S-Corp

On 20 April 2007, the Finance Court Cologne revised its previous decision of 16 February 2006 on the reduction of dividend withholding taxes (WHT) under the Germany-US income tax treaty in the case of a US S-Corporation which elected to be tax transparent under US tax rules. Details of the decision are summarized below.

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