SUMMARY
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
RESIDENT PERSON
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
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