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In a recent ruling, dated 9 September 2010 (I R 7409), the Federal Fiscal Court (Bundesfinanzhof) decided (again) on the tax treatment of so-called special payments (Sondervergütungen) pursuant to Sec. 15 (1) s. 1 No. 2 ITA) by a German partnership to a US resident partner under the applicable double tax treaty (DTT
