donochitwa (Mar 30 2011, 02:04 PM) said: > original post
Hi There, Not sure about the Swiss side, but the U.S. side has Tax implications on IRA's when Citizenship is renounced. Suggest you contact a Tax Accountant or Tax Attorney in the USA. to establish how the U.S. is going to treat this account because of Citizenship issue.

Don,

According to the US and Swiss treaty, if your Mother is no longer a US person for tax purposes, and is currently a resident of Switzerland, then no US taxes are due on a distribution as long as Swiss taxes are paid and the distribution is declared in Switzerland. Your mother will declare the income in the canton where she lives and this "income" will be subject to the same tax rates as a lump sum distribution from a 2nd pillar in Switzerland, generally between 6-12% depending on the canton...I have had several clients do this without a problem...in Switzerland you can contact Leman Cabinet Fiscal, they know the Swiss side; I am not affiliated with them....