[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: 26CFR509.114]

[Page 45-46]
 
                       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. 509.114  Private pensions and life annuities.

    (a) General. Private pensions and life annuities derived from 
sources within

[[Page 46]]

the United States and paid to a nonresident alien individual who is a 
resident of Switzerland shall not be included in gross income and shall 
be exempt from United States tax, in accordance with Article XI of the 
convention, even though at some time during the taxable year such 
individual has engaged in trade or business in the United States through 
a permanent establishment situated therein.
    (b) Definitions. As used in this section, the term ``pensions'' 
means periodic payments made in consideration for services rendered or 
by way of compensation for injuries received; and the term ``life 
annuities'' means a stated sum payable periodically at stated times 
during life, or during a specified number of years, under an obligation 
to make the payments in return for adequate and full consideration in 
money or money's worth.