LEX USA - Professor Allison Christian: "Switzerland already has a double tax treaty with the USA so even if the Switzerland IGA was the kind that theoretically needs a DTT (double tax treaty) to "interpret" (namely, a Model 1-style), the treaty needed is already in place, with language on information sharing ready to be "interpreted" by an IGA. However, Switzerland has not signed a Model 1 IGA with the US, it has signed a so-called "Model 2" IGA, which is non-reciprocal and binds the US to virtually no action whatsoever. It is for this reason, perhaps, that Treasury has already claimed that Model 2 agreements do not even need a treaty to interpret: that is, the Treasury has suggested that even non-treaty countries can get a Model 2 IGA. So you never need a treaty with Switzerland to implement the proposed IGA. Blocking the Swiss treaty may do a lot of things, but stopping the FATCA IGA is most certainly not one of them." taxpol.blogspot.ca/2013/05/correcting-record-5-ways-on-stories.html
Posted on: Tue, 18 Jun 2013 22:32:44 +0000
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