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15849 1 (2016)

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US. GOVERNMENT
INFORMATION
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                    114TH CONGRESS                                    ExEc. REPT.
                      2d Session                SENATE                   114-1



                             PROTOCOL AMENDING TAX CONVENTION
                                        WITH   SWITZERLAND


                                   FEBRUARY 9, 2016.-Ordered to be printed


                         Mr. CORKER,  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 rpose  ...........................................................................................................  1
                      II. B ackground  ....................................................................................................  2
                      III.  M ajor  Provisions  ............................................................................................  2
                      IV .  Entry  Into  Force  ............................................................................................  3
                      V. Im plem enting  Legislation  ...........................................................................  3
                      VI. Com m ittee  Action  ..........................................................................................  3
                    VII. Com m ittee  Com m ents  .................................................................................  3
                    VIII. Text of Resolution of Advice and Consent to Ratification ........................  7
                    IX. Annex 1.- Technical Explanation  ................................................................  11
                    X.  Annex 2.-Transcript of Hearing of October 29, 2015 ................................  23
                                              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-
                       59-119

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