This is a technical explanation of the Protocol signed at Berlin on June 1, 2006 (the "Protocol"), amending the Convention between the United States of America and the Federal Republic of Germany for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital and to certain other taxes, and the related protocol, signed at Bonn on August 29, 1989 (hereinafter the "Convention" and "Protocol to the Convention" respectively).