Professional Articles & Publications
Since 2020, I, Resso Bulut, have regularly published articles and case notes in IStR, DStR-K and GmbH-Steuerpraxis. To date, more than 25 contributions have been published, focusing in particular on international tax law, investment taxation, corporate reorganisation tax law and double taxation agreements.
A selection of my publications is provided below.
Full-Text Access
Articles published in IStR and DStR-K are available via beck-online. Articles published in GmbH-Steuerpraxis can be accessed through VSRW Verlag. The underlying decisions of the German Federal Fiscal Court (Bundesfinanzhof – BFH) are available free of charge.
Broad Interpretation of the Concept of Control in the Current Administrative Guidance on the German Foreign Tax Act – Areas of Uncertainty and Their Implications for Investment Funds
Case Note on the "Bull–Bear Model" (Offsetting Certificates) and the Abuse of Tax Planning Doctrine
Book Value Election under Section 3(2) UmwStG and the Determination of an Acquisition Loss under Section 4(6) UmwStG
Case Note on Deemed Unlimited Tax Liability for Recipients of a Statutory Pension Resident in Norway
Critical Observations on the New Section 6 InvStG – A Structural Break Introduced by the Growth Opportunities Act?
Free Allocation Decisions by Investment Funds Prior to the Introduction of Section 3a InvStG 2004
No Dissolution of Negative Supplementary Tax Balance Sheets Created for Existing Partners Following the Admission and Subsequent Departure of a New Partner
Germany's Taxing Rights over a Statutory Pension Paid to a German National Resident in Italy
Tax Privileges for So-Called "Millionaire Funds" Confirmed
Mutual Transfers of Shares in Corporations (Share Rotation) Below Market Value
Foreign Sickness Benefits and Investment Income under the Regime of Deemed Unlimited Tax Liability and the Progression Clause
Allocation of Retirement Income Received by a Retired European Patent Office Official
Taxation of Remuneration Paid to an Interpreter Working on a Daily Basis for the Council of Europe
The Post-Demerger Disposal Restriction under Section 15(2), Sentences 3 and 4 UmwStG as a Uniform Anti-Avoidance Rule
Tax-Neutral Allocation of Shares in a US Spin-Off to Private Investors Resident in Germany
The Term "United Labour Organisation" in the Germany–Yugoslavia Double Taxation Agreement Also Covers Successor Organisations
Breach of the Lock-Up Period under Section 6(5), Sentence 6 EStG through the Tax-Neutral Conversion of an Upper-Tier Partnership
Evidence of Foreign Taxation of Employment Income
Deductibility of Pension Contributions Where Employment Income Earned in Switzerland Is Exempt from German Tax
Blog Articles
In addition to my professional publications, I write about current developments in tax law and my approach to tax advisory in this blog.
