In this article written in German for Frankfurter Allgemeine Zeitung, Loren Ponds and Axel Bodefeld of Kanzlei Oppenhoff discuss Germany's taxation of foreign corporations' income derived from patents and trademarks registered with the German Patent and Trademark Office in Munich. They argue that this policy shift deviates from previous German tax norms and international transfer pricing principles, resulting in extraterritorial taxation that disproportionately impacts U.S. companies. They highlight the U.S. Tax Cuts and Jobs Act (TCJA) of 2017, which reformed the U.S. international tax system by introducing measures like Section 965's one-time transition tax on foreign earnings and Section 951A which regulates global low-tax intangible income (GILTI) for controlled foreign corporations (CFCs). Ponds and Bodefeld stress the importance of Germany avoiding double taxation on income already taxed under U.S. law, emphasizing the need for alignment between international tax regimes to prevent undue financial burdens on U.S. companies.