According to the information provided the test may be summarized as follows :

The information included in the present tool is intended as general guidance and is not represented to be comprehensive or advisory in nature. Please contact your professional tax adviser for detailed information regarding the topic contained herein


The person receiving the income is a Swiss resident family foundation

The founder or the majority of the beneficiaries are not Swiss or US resident individuals and 50% or less of the income benefits Swiss or US resident individuals

Under these circumstances treaty protection is not granted