From: Bela Ban < >
Date: Fri, 11 Feb 2000 09:11:15 -0500
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Status: RO

> According to the IRS (with no commitment from their side), the tax
> treaty with Switzerland was modified to disallow this option, as of
> Jan 1, 1998 with a one year delay for applying the new treaty. (Some
> claim it was Feb, 1998.) In fact, various people at IRS have given
> various intructions.

Yes, I also heard that the tax treaty between Switzerland and the US was
terminated, but I'm not exactly sure when. However, there is a grace period
of 1 year (the Grandfather clause). So, if the above date of termination of
Jan 98 is correct, anyone on a J1 would be taxable starting Jan 99. So if
I'm correct, in this case the substantial presence test would have to be
applied to show whether you are considered resident for tax purposes (can't
remember the exact rule).
Bela

--
Bela Ban
bela_at_somm.com
+41 71 666 77 40
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