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Essay / Research Paper Abstract
This 3-page paper discusses the double-tax treaty between the U.S. and Switzerland, including the exchange of information annex. Bibliography lists 3 sources.
Page Count:
3 pages (~225 words per page)
File: AS43_MTdoubltax.rtf
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Unformatted sample text from the term paper:
earned in Switzerland, without a double-tax treaty, the company is taxed on the profits earned in Switzerland - and also on profits earned by the U.S. tax system. Because of
this, many countries have opted to formulate a double-tax treaty so companies and individuals working at these companies avoid being taxed by their host country and their home country.
The Tax Convention with the Swiss Confederation, as the double-tax treaty between Switzerland and the U.S. is known, replaced the Avoidance of Double Taxation
with Respect to Taxes on Income signed in May, 1951 (Tax Convention with Swiss Confederation, 1996). At the time, the letter of
submittal on the new document indicated that the convention had many of the provisions of the 1950s convention, but "also provides certain additional benefits" and offered updates to reflect tax
treaty policies (Tax Convention with Swiss Confederation, 1996). From that time to recently, the double tax treaty was modified once again, with the United States introducing a provision
on the exchange of information and an arbitration clause - both of which were in accordance with the OECD Model convention (Stahler, 2009). The Organization for Economic and Cooperation and
Developments model focuses, in many regards, on exchange of information - and this is important when it comes to the U.S.-Switzerland treaties. Since the time of the August signing, and
until November 17, 2009, the Swiss and U.S. have signed two amendments to that original treaty. The recent agreement signed involved a request for information from the IRS regarding UBS;
and was an annex to the agreement that specified criteria and information for granting the assistance (Amon, 2009). Previous to that, in September 2009, the new protocol between the
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