The U.S. IRS has issued Announcement 2025-08 on a competent authority arrangement (CAA) signed with Switzerland in December 2024 regarding the eligibility of certain U.S. and Swiss pension or other retirement arrangements, including individual retirement savings plans, for benefits (exemption) under paragraph 3 of Article 10 (Dividends) of the 1996 tax treaty between the two countries. Paragraph 3 of Article 10 provides that dividends may not be taxed in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is a pension or other retirement arrangement which is a resident...