Switzerland and the United States have signed a new Competent Authority Arrangement regarding the eligibility of certain US and Swiss pension and other retirement arrangements for treaty benefits under the double tax treaty between the two countries.The new Competent Authority Arrangement has implications for US 81-100 Group Trusts' applications for Swiss taxes withheld on dividend income. Executive summaryIn December 2024, Switzerland and the United States signed a new Competent Authority Arrangement (CAA) regarding certain US and Swiss pension and other retirement arrangements' eligibility for treaty benefits under the double tax treaty between the two countries.While the new CAA retains most of...