[Code of Federal Regulations]
[Title 26, Volume 18, Parts 500 to 599]
[Revised as of April 1, 2000]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR509.121]

[Page 49]
 
                       TITLE 26--INTERNAL REVENUE
 
     CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY 
                               (Continued)
 
PART 509--SWITZERLAND--Table of Contents
 
                       Subpart--General Income Tax
 
Sec. 509.121  Beneficiaries of an estate or trust.

    (a) Qualified beneficiary. If he otherwise satisfies the 
requirements of the respective articles concerned, a nonresident alien 
who is a resident of Switzerland and who is a beneficiary of an estate 
or trust shall be entitled to the exemption from, or reduction in the 
rate of, United States tax granted by Articles VI, VII, VIII, and XIV of 
the convention with respect to dividends, interest, and royalties and 
other like amounts, to the extent that (1) any amount paid, credited, or 
required to be distributed by such estate or trust to such beneficiary 
is deemed to consist of such items and (2) such items would, without 
regard to the convention, be includible in his gross income.
    (b) Amounts otherwise includible in gross income of beneficiary. For 
the determination of amounts which, without regard to the convention, 
are includible in the gross income of the beneficiary, see subchapter J 
of chapter 1 of the Internal Revenue Code of 1954, and the regulations 
thereunder.