This paper provides evidence that nominative arguments in German and Icelandic not only can be analyzed as remaining in the VP overtly, but that in some constructions, these arguments remain internal to VP at all levels of representation, including LF. The paper reviews a variety of recent proposals for Case licensing and argues that only the Agree model (Chomsky 2000) provides for a unified account of Case licensing. Specifically, I argue that languages like German lack any syntactic or phonological requirement that Spec,TP be filled (thus that the EPP is not universal) and provide empirical arguments against theories invoking Case transmission and null expletives. Although German lacks the EPP, arguments are also provided that German does have TP and related functional projections.