WTS US

U.S. Tax Planning for Investments in Foreign Portfolio Companies

Reprinted from The Journal of Private Equity, Winter 2004 [.pdf] A Dollar of Prevention Is Worth a Pound (or Euro) of Cure Domestically, private equity and venture capital investment structures have become increasingly standardized. Due to their familiarity, this has lead to a tendency for funds to use the same or similar structures for non-U.S. [...]

Protocol to German / U.S. Tax Treaty (2006)

On June 1, 2006 representatives of Germany and the United States signed a new Proto-
col to amend the existing income tax treaty between the two countries (the “Treaty”).
Highlights of the Protocol include zero percent withholding on certain dividends and a
more comprehensive limitation on benefits (LOB) article.

Set forth below is a summary of some of the most significant changes affecting corpora-
tions.