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Old 08.01.2015, 14:05
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Re: IRS Coming to Switzerland - literally!

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Tina Masuda is (or was) accredited as the IRS Representative in Paris, which means she has diplomatic immunity in France and travels on a diplomatic passport. That passport gives her no immunity in Switzerland, except that as a matter of diplomatic courtesy she would (as a matter of Foreign Ministry discretion) enjoy functional immunity for her official acts.

She will undoubtedly be discreet in the exercise of her function within Switzerland.

If (and only if) the Embassy in Bern notified the Foreign Ministry of her expected arrival and asked for her inclusion on the diplomatic list, she would enjoy full immunity. In difficult countries (the old USSR, many countries in Africa, etc.) it is State policy to notify the host country's foreign ministry of every official TDY visit, however brief, to assure immunity. That ensued from a contretemps in Benin where TDY communicators were arbitrarily arrested while driving out of the country in the 1970s.

IRS attachés have little or no policy responsibility and are there to provide limited taxpayer assistance and to coordinate with host country tax authorities on "Competent Authority" treaty issues, including exchange of taxpayer data.
The IRS Tax Attaché in Paris is Aziz Benbrahim. A quick Google search shows that he is accredited in a number of European, African and Middle East countries, although I did not find him as accredited in Switzerland.

As of several years ago, according to a Google search, the IRS office in Paris had five employees. It could be expected that most will be traveling to Switzerland to handle the 40+ one-on-one "consultations" with US taxpayers and also the presentation at the AWCZ.
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