I read the link, and included is the text from the signed agreement with the USA and Switzerland. Does anyone know if additional memorandum of understanding has been issued regarding the dividends from pension accounts and the fact that they no longer will need to be reported to IRS?

From my reading of this, it will mean that 3a pillar will no longer need to be reported to the IRS.
Thanks in advance if anyone has any additional official information. I have started to pull my tax documents together for IRS.


The Protocol contains a new version of Article 10(3) that expands the scope of beneficial owners entitled to the zero rate of withholding tax to include individual retirement savings plans that are set up in, and owned by a resident of, the other Contracting State. Dividends received from a controlled payor remain ineligible for the elimination of withholding tax under the Protocol. In addition, in order to be eligible for the zero rate of withholding under the Protocol's new version of Article 10(3), the competent authorities of the Contracting States must agree that the pension or other retirement arrangement, or individual retirement savings plan, would generally be recognized as such for tax purposes in the other Contracting State. Although the Protocol does not contain details as to how taxpayers are to substantiate their satisfaction of this requirement, it is likely that a Memorandum of Understanding or Exchange of Notes accompanying the Protocol will provide the necessary guidance.