@pk
Can you please explain exactly how this is done and how this works?
I am sorry, this is still not clear. Are you suggesting that the entire US source dividend be "re-sourced" as foreign dividend, to avoid paying any tax in USA. However, per Germany/USA double taxation treaty, US reserves the right to tax 15% of the mutual fund dividends. So in your case where and how would USA get its share of 15%.
Aren't the 're-sourcing" rules to avoid USA from taxing more than 15% (e.g. in case of non qualified dividends for high income earners?).
Thanks a bunch,
SK
