Das Optionsmodell zur Körperschaftsbesteuerung nach § 1a KStG

'The Election to Be Taxed as a Corporation under Section 1a of the German Corporate Income Tax Act': Section 1a of the German Corporate Income Tax Act (KStG) allows certain partnerships, for the first time, to elect to be taxed as corporations without having to change their legal form under civil law. The author critically examines the constitutionality of this election, the requirements imposed by company law on a resolution to exercise the election or to revert to partnership taxation, and its tax consequences in an international context, with particular attention to cross-border profit distributions.