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U.S.-Switzerland Tax Planning and Traps to Avoid: Reporting Issues, Tax Treaties, Passive Income, Pass-Through Income

A live 90-minute premium CLE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Thursday, June 5, 2025

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, May 9, 2025

or call 1-800-926-7926
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This CLE/CPE course will provide tax counsel and advisers with a practical guide into issues that arise in relation to the tax reporting requirements and planning opportunities for U.S. taxpayers with earnings or assets in Switzerland, as well as Swiss citizens with U.S. tax reporting obligations. The panel will discuss U.S. tax law and treaty provisions designed to avoid or mitigate dual taxation, give an overview of Swiss residence and domicile rules, and detail potential treaty benefits.

Description

The U.S. and Switzerland have significant economic and social ties resulting in a constant flow of cross-border business transactions and citizens migrating between the two countries. Tax counsel and advisers must navigate challenges stemming from the interpretation and enforcement of U.S. and Switzerland tax rules to avoid adverse tax liability from either country.

Among the most critical planning challenges for cross-border activities is reconciling the U.S. and Switzerland rules governing residence and domicile. Switzerland domicile rules are complex, and even inadvertent failure to meet filing obligations due to a misapplication of domicile rules can be costly. U.S. tax advisers serving clients with a presence in the U.S. and Switzerland will need to understand the domicile rules to avoid costly tax and penalties.

Another critical planning element is avoiding dual taxation on income and gains. The U.S. has detailed domestic foreign tax credit rules, along with a comprehensive tax treaty with Switzerland that together address most dual taxation concerns, but, as in all international planning, tax advisers must understand the particular provisions to avoid an unpleasant tax bill--or maybe two.

Other areas of concern in U.S.-Switzerland tax planning include treatment of passive income and tax considerations of cross-border pension ownership, contributions, and withdrawals. Hovering over all these concerns are the extensive U.S. tax reporting requirements imposed on taxpayers with U.S. filing obligations.

Listen as our experienced panel provides comprehensive and practical guidance on navigating U.S.-Switzerland cross-border tax planning and reporting issues.

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Outline

I. The U.S.-Switzerland income tax treaty overview and dual tax mitigation provision

II. Domicile and residency rules

III. Passive and unearned income treatment

IV. U.S. tax reporting requirements of Switzerland-sourced investments

V. Limitation of benefit provisions

Benefits

The panel will review these and other important topics:

  • What are the applicable domestic and treaty provisions for mitigating dual taxation on ownership of cross-border pass-through entities and trusts?
  • Limitation of benefits clauses and provisions in the U.S.-Switzerland income tax treaty
  • Key risks and challenges of passive/unearned income in cross-border situations
  • U.S. reporting requirements of Switzerland-sourced investments


Faculty

Chaffin, Savannah
Savannah Chaffin
Enrolled Agent, Founder/Lead Tax Advisor
Alveus Tax

Ms. Chaffin is a U.S. citizen living abroad specializing in tax and financial planning services for fellow...  |  Read More

Mazur, Dominik
Dominik Mazur, LL.M.
Partner
Lindemann Law

Mr. Mazur is a partner and tax leader at LINDEMANNLAW, where he provides advice on tax and legal matters to...  |  Read More

Tucker, Ariel
Arielle Tucker
CFP & Enrolled Agent
Connected Financial Planning

Ms. Tucker has spent over a decade working on personal tax and financial planning issues for clients who, like...  |  Read More

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Early Discount (through 05/09/25)

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Early Discount (through 05/09/25)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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