Sabine Rödel presents the fundamental concept of income qualification based on the catalog of facts of the 8th Foreign Tax Act (AStG), taking into account a functional perspective. She places particular emphasis on income from profit distributions of corporations as well as income from realization events. Through typical practical cases, she analyzes the foreign tax implications of foreign transformations without direct domestic relevance for domestic shareholders. The foreign tax treatment of transformations of foreign entities without a registered office and management in the country repeatedly leads to problems in practice. In light of the introduction of the unrestricted holding privilege and the restricted activity regulation for realization gains on one hand, and the abolition of Section 10 (5) of the AStG on the other, this topic has gained significant relevance.