The time is rapidly approaching for US tax return, and I can not get an answer on if the 3a divedend is nolonger needed to be declared.   I just read at the ACA.ch website that the tax treaty has just been ratified.It is not clear to me after the Sept 2009 tax agreement between US and Switzerland that the 3rd pillar is taxable in the USA.

The text of the tax agreement signed in September 2009 can be seen at:
http://www.pwc.ch/user_content/edito...mending_us.pdf

From my reading of this, it will mean that 3a pillar divedends will no longer need to be reported to the IRS for tax purposes. The account, will need to be declared per requirements that US citizens report all accounts whose total balance is above $10,000.

The Protocol contains a new version of Article 10(3) that expands the scope of beneficial owners entitled to the zero rate of withholding tax to include individual retirement savings plans that are set up in, and owned by a resident of, the other Contracting State. Dividends received from a controlled payor remain ineligible for the elimination of withholding tax under the Protocol. In addition, in order to be eligible for the zero rate of withholding under the Protocol's new version of Article 10(3), the competent authorities of the Contracting States must agree that the pension or other retirement arrangement, or individual retirement savings plan, would generally be recognized as such for tax purposes in the other Contracting State. Although the Protocol does not contain details as to how taxpayers are to substantiate their satisfaction of this requirement, it is likely that a Memorandum of Understanding or Exchange of Notes accompanying the Protocol will provide the necessary guidance.

Does anyone know if additional memorandum of understanding has been issued regarding the dividends from pension accounts and the fact that they no longer will need to be reported to IRS?'