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15390 1 (2011)

handle is hein.usccsset/usconset50039 and id is 1 raw text is: AUTHENTICATEO
U.S. GOVERNMENT
INFORMATION
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                   112TH CONGRESS              SEAEExEc. REPT.
                      1st Session              SENATE                   112-1



                         PROTOCOL AMENDING TAX CONVENTION WITH
                                           SWITZERLAND


                         AUGUST 30 (legislative day, AUGUST 2), 2011.-Ordered to be printed


                         Mr. KERRY, 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,
                   together with a related agreement effected by an exchange of notes
                   on September 23, 2009 (Treaty Doc. 112-1) (collectively, the Pro-
                   tocol), having considered the same, reports favorably thereon with
                   one declaration, as indicated in the resolution of advice and con-
                   sent, and recommends that the Senate give its advice and consent
                   to ratification thereof, as set forth in this report and the accom-
                   panying resolution of advice and consent.
                                              CONTENTS
                                                                                Page
                      I. P u rpose  ...........................................................................................................  1
                      II.  B ackground  ....................................................................................................  2
                    III. M ajor  Provisions  ............................................................................................  2
                    IV . E ntry  Into  Force  ...........................................................................................  3
                    V.  Im plem enting  Legislation  .............................................................................  3
                    V I. Com m ittee  A ction  .........................................................................................  3
                    VII. Com m ittee  Com m ents  ...................................................................................  3
                    VIII Text of Resolution of Advice and Consent to Ratification .......................... 5
                    IX. Annex 1.- Technical Explanation  ...............................................................  7
                    X. Annex 2.- Transcript of Hearing of June 7, 2011  ......................................  19
                                              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
                      99-115

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