@Markus W , while I generally agree with my colleague @Opus 17 , I have doubts about the tax treatment of the pension scheme you are talking about. The tax treaty between US and Germany talks ONLY about pension from gov t. sources in the two countries. As far as I know Germany has different kinds of pension schemes ( both defined benefit and defined contribution ) including some specifically for professionals . This is further complicated by lack of knowledge on whether this "pension" that you are talking about is based is your private insurance or one that is shared with your employer ( I am assuming that you worked for a German entity / branch thereof in the USA). The treaty and its updated protocols/ technical explanations etc. leave me kind insecure in hazarding a guess as to the taxability of the income/ gain.
Therefore any explanation as to what you actually did and the type of plan that you contributed to would be most helpful.
I do understand that if nothing better comes out of this discussion, then @Opus 17 would be correct in treating this as a pure and unqualified investment where all the gain is taxable to the US.
pk
