KPMG is reporting that the Announcement 2021-11 from the Internal Revenue Bulletin 2021-14 (June 7, 2021) includes a competent authority arrangement as entered into by the competent authorities of the United States and Switzerland. The article begins as follows:
The competent authority arrangement implements a provision of a 2009 Protocol to the United States-Switzerland income tax treaty that, in relevant part, added individual retirement savings plans (IRSPs) to the list of U.S. and Swiss pension or other retirement arrangements that may be eligible for beneficial treatment under paragraph 3 of Article 10 (Dividends).
See the full KPMG article by clicking: Individual savings plans eligible for dividend benefits under United States-Switzerland tax treaty (June 4, 2021).
See Part IV of IRS Bulletin 2021-23, Announcement 2021-11, click here.
Posted by Jessica Ji, Associate Editor, Wealth Strategies Journal.