How does the German Finanzamt treat U.S. disregarded entities?
My Steuerberater says Germany will tax my U.S. LLC as if it were a GmbH. But my U.S. CPA says the LLC is disregarded and I do not owe U.S. corporate tax. This mismatch means I am paying German corporate tax on income that was never taxed in the U.S. at the entity level. How is this fair, and what can I do? Can the Rechtstypenvergleich result in transparent treatment if I structure the LLC operating agreement correctly?
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