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Introduction

Investing in U.S. real estate can be highly rewarding, but it comes with complex tax regulations. Rockfish Capital Germany GmbH is structured to maximize tax efficiency for international investors. Thanks to the U.S.-Germany tax treaty, Rockfish investors avoid direct U.S. tax filings, withholding taxes, and FATCA compliance burdens.

This guide explains how Rockfish Capital Germany GmbH ensures a seamless, tax-efficient investment process for international investors.

Why Rockfish Investors Avoid U.S. Tax Filings

One of the biggest concerns for non-U.S. investors in U.S. real estate is having to file U.S. tax returns or receive K-1 forms. However, Rockfish Capital Germany GmbH acts as a blocker entity, which means:

• Investors do not receive K-1 forms from U.S. partnerships.
• Investors do not need to file U.S. tax returns.
• Rockfish handles all U.S. tax compliance at the entity level, removing investor liability.

How Rockfish Avoids U.S. Withholding Taxes

Under standard U.S. tax law, foreign entities investing in U.S. assets may face a 30% withholding tax on U.S. income(e.g., interest, dividends, rental income). However, Rockfish Capital Germany GmbH benefits from the U.S.-Germany tax treaty, which allows:

• Reduced or eliminated withholding tax rates when proper filings are made.
• Rockfish to claim treaty benefits via Form W-8BEN-E, preventing automatic tax withholding.
• Taxation to be handled at the entity level, avoiding complications for investors.

Key Tax Filings Rockfish Completes (So Investors Don’t Have To)

To maintain its tax-efficient structure, Rockfish Capital Germany GmbH handles the following filings:

• Form W-8BEN-E – Provided to U.S. partnerships/funds to claim U.S.-Germany treaty benefits and prevent withholding tax.
• K-1 Forms Received by Rockfish – Rockfish receives and processes K-1s internally, ensuring investors are not directly impacted.
• Form 1120-F (U.S. Tax Return) – Filed by Rockfish only if it has taxable U.S. income, ensuring compliance while preventing unnecessary tax withholding.

FATCA Compliance: No Direct Investor Reporting Required

Rockfish Capital Germany GmbH could be classified under FATCA as either a Passive Non-Financial Foreign Entity (Passive NFFE) or a Foreign Financial Institution (FFI), depending on its specific operations. Typically, this means:

• Investors are not subject to direct FATCA reporting obligations.
• Rockfish provides Form W-8BEN-E to financial institutions to ensure compliance.
• Investors should consult their tax advisors to confirm whether regulatory requirements may change.

Summary: Rockfish’s Tax Advantages for Investors

• No K-1 Forms – Rockfish absorbs U.S. tax reporting obligations.
• No U.S. Tax Filings for Investors – All taxation is handled at the entity level.
• No Withholding Tax – The U.S.-Germany tax treaty ensures tax efficiency.
• FATCA Compliance Ensured – Rockfish manages FATCA requirements and ensures all regulatory obligations are met.

Conclusion

Rockfish Capital Germany GmbH is designed to provide maximum tax efficiency and compliance while eliminating unnecessary burdens for investors. By leveraging the U.S.-Germany tax treaty and structured tax filings, Rockfish ensures that international investors can participate in U.S. real estate without dealing with direct tax obligations.

Disclaimer

This guide is for informational purposes only and does not constitute tax, legal, or financial advice. The information provided is based on current laws and regulations, which may be subject to change. Rockfish Capital Germany GmbH makes no guarantees regarding tax treatment or compliance obligations and assumes no liability for decisions made based on this content. Investors should consult qualified legal and tax professionals to assess their specific situation before making any investment decisions.