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Old 23.05.2012, 10:35
runningdeer runningdeer is offline
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Re: US Tax Basics 101

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So in fact the treaty is not designed to avoid double-taxation, but rather designed to avoid TRIPLE-taxation. Since it is common knowledge that the 2nd pillar will be taxed in Switzerland upon pay-out (no grey area there), the US renounces also taxing it on pay-out, but resigns itself to "just" taxing the pay-ins? Rather than duking it out and fighting for scraps, the two countries collude to double-tax? If it's true that the US-UK treaty is much better designed in this respect, why the IRS's "willful" intention to double-tax in the case of Switzeland?
Remember the Swiss-US tax treaty is quite old, before a lot of this came to the forefront, much before FATCA, UBS cases, etc.. They keep signing new tax treaties between themselves (US-CH), but none has been put into force yet. From what I recall of the media reporting, it seems as they keep unearthing new pieces of the UBS case, and now taking it further to other banks, the Swiss side is only concerned with this aspect. US side is of course only out for stronger enforcement on this and similar Fatca type, these are still on-going and the main concerns, thus pensions and other 'frivioous' nuiances get put aside. Only some intense lobbying on the side of US and CH will likely get this solved.
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