Foreign partners in German partnerships shouldtake note of the new statutory treatment of specialpayments (Sondervergütungen) now codified in section50d paragraph 10 of the Income Tax Act (Einkommensteuergesetz,or EStG). The question iswhether these special payments qualify as businessprofits...

[...]Drafting antiavoidance legislation is one of thebiggest challenges of modern tax law. The English,German, and French languages have long had thesaying ‘‘Don’t throw the baby out with the bathwater.’’ Only those with a sharp tongue would evercontend that this saying serves as a...