Module 4.5 — Other jurisdictions: Germany, UK, and the US PFIC trap Three more tax regimes that shape how European ETF investors should think, plus the structural rule that keeps US persons out of UCITS funds. Germany: the Vorabpauschale. Germany taxes ETF investors via a Teilfreistellung (partial exemption) and Vorabpauschale (pre-payment) mechanism designed to neutralise…