Code of Federal Regulations (Last Updated: November 8, 2024) |
Title 26 - Internal Revenue |
Chapter I - Internal Revenue Service, Department of the Treasury |
SubChapter G - Regulations Under Tax Conventions |
Part 509 - Switzerland |
Subpart A - Withholding of Tax |
§ 509.5 - Pensions and life annuities.
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Article XI(2) of the convention provides that private pensions and life annuities derived in taxable years beginning on or after January 1, 1951, from sources within the United States by a nonresident alien individual who is a resident of Switzerland shall be exempt from United States tax.
The person paying such income shall be notified by letter from the resident of Switzerland that the income is exempt from taxation under the provisions of Article XI (2) and (3) or XI (2) and (4), as the case may be, of the convention. Such letter shall contain the address of the individual and a statement that such individual is a resident of Switzerland. The letter of notification, or a copy thereof, shall be immediately forwarded by the recipient to the Commissioner of Internal Revenue, Records Division, Washington, D.C. Such letter shall constitute authorization to the payor of the income to pay such income without deduction of the tax at the source unless the Commissioner subsequently notifies such payor that the tax should be withheld with respect to payments made after such notification.