§ 509.10 - Beneficiaries of a domestic estate or trust.

A nonresident alien who is a resident of Switzerland and who is a beneficiary of a domestic estate or trust shall be entitled to the exemption from tax, or reduction in the rate of tax, as the case may be, provided in Articles VI, VII, and VIII of the convention with respect to dividends, interest, and royalties to the extent such item or items are included in his distributive share of the income of such estate or trust. In such case such beneficiary must, in order to be entitled to the exemption from, or reduction in the rate of, tax in the case of interest or royalties, execute Form 1001A-S and file such form with the fiduciary of such estate or trust in the United States.