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Protocol Amending the Convention between The United States of America and The � Federal Republic of Germany for the Avoidance of Double Taxation and the � Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital and to � Certain Other Taxes Please note that the text of this Convention starts two-thirds of the way down this � page. The page layout of this file reflects the layout of the original signed treaty � document. This document is designed to print on 8 by 14 legal size or

Article 13 (Gains) of the Convention is modified by deleting paragraph 6 and substituting

U.S. Income Tax Treaty — germany tax treaty documents: germanprot06.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

the following new paragraph:

“6. Where an individual who, upon ceasing to be a resident of one of the Contracting

States, is treated under the taxation law of that State as having alienated property and is

taxed in that State by reason thereof, the individual may elect to be treated for purposes

of taxation in the other Contracting State as if the individual had, immediately before

ceasing to be a resident of the first-mentioned State, alienated and reacquired the property

for an amount equal to its fair market value at that time.”

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▸Contents — U.S. Income Tax Treaty — germany tax treaty documents: germanprot06.pdf
U.S. Income Tax Treaty — germany tax treaty documents: germanprot06.pdf

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