[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: 26CFR509.113]
[Page 45]
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. 509.113 Government wages, salaries, and pensions.
(a) General. Under Article XI of the convention any wage, salary, or
similar compensation, or any pension, paid by Switzerland or any agency
or instrumentality thereof, or by any political subdivisions or other
public authorities of Switzerland, to any alien individual (whether or
not a resident of the United States) or to any individual who occupies
the dual status of a citizen of the United States and a citizen of
Switzerland shall not be included in gross income and shall be exempt
from United States tax, 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) Definition. 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. Under Article XV(2) of the
convention the exclusion from gross income, and exemption from United
States tax, provided by this section shall not be denied despite the
provisions of Article XV. See Sec. 509.118.
(c) Cross reference. For the taxation generally of compensation of
alien employees of foreign governments and the consequences of executing
and filing the waiver provided for in section 247(b) of the Immigration
and Nationality Act, see section 893 of the Internal Revenue Code of
1954 and the regulations thereunder.