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Ex. Rept. 116-2 1 (2019-07-10)

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                   116TH CONGRESS              SN                  I EXEC. REPT.
                      1st Session JSENATE                               116-2



                            PROTOCOL AMENDING TAX CONVENTION
                                        WITH SWITZERLAND


                                     JULY 10, 2019.-Ordered to be printed


                          Mr. RISCH, from the Committee on Foreign Relations,
                                        submitted the following

                                             REPORT
                                      [To accompany Treaty Doc. 112-1]
                     The Committee on Foreign Relations, to which was referred the
                   Protocol Amending the Convention between the United States of
                   America and the Swiss Confederation for the Avoidance of Double
                   Taxation With Respect to Taxes on Income, signed at Washington
                   on October 2, 1996, signed on September 23, 2009, at Washington,
                   as corrected by an exchange of notes effected November 16, 2010,
                   and a related agreement effected by an exchange of notes on Sep-
                   tember 23, 2009 (Treaty Doc. 112-1) (collectively, the Protocol),
                   having considered the same, reports favorably thereon with one
                   declaration and conditions related to reporting on mandatory arbi-
                   tration, as indicated in the resolution of advice and consent, and
                   recommends that the Senate give its advice and consent to ratifica-
                   tion thereof, as set forth in this report and the accompanying reso-
                   lution of advice and consent.

                                              CONTENTS
                                                                                Page
                      I. P u rp o se  ...........................................................................................................  1
                      II.  B ack grou n d  ...................................................................................................  2
                    III. M ajor  P rovision s  ...........................................................................................  2
                    IV . E n try  Into  F orce  ...........................................................................................  3
                    V . Im plem enting  Legislation  .............................................................................  3
                    V I. C om m ittee  A ction  .........................................................................................  3
                    V II.  Com m ittee  Com m ents  ...................................................................................  4
                    VIII. Text of Resolution of Advice and Consent to Ratification .......................... 8
                    IX. Annex 1.- Technical Explanation  ................................................................  11
                                             I. PURPOSE
                     The purpose of the Protocol, along with the underlying treaty, is
                   to promote and facilitate trade and investment between the United
                   States and Switzerland, and to bring the existing treaty with Swit-
                   zerland (the Treaty) into conformity with current U.S. tax treaty
                      89-119

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