On 23 September 2009, Switzerland and the United States signed a protocol to the 1996 tax treaty along with an exchange of notes (see US Department of Treasury press release and Swiss Confederation press release). The full texts are available from the US Department of Treasury website. Art. 1 of the protocol replaces Para. 3 of Art. 10 (Dividends) of the 1996 treaty. It generally provides that dividends will not be taxed in the Contracting State of the company paying the dividends if the beneficial owner is a pension, other retirement arrangement that is a resident of the other Contracting...