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Hello and thanks for trusting me to help you today. I am a tax adviser with over 15 years of experience.The IRS would only recognize an account or plan that was under the US for reporting requirements. If the funds were transferred that, unfortunately would not be a rollover in tax terms for deferring the tax.
The Swiss plan would need to be a qualified plan under the IRC of the US,
In general if you are under age 59½ at the time of the distribution, any taxable portion not rolled over may be subject to a 10% additional tax on early distributions unless an exception applies.
Unfortunately, even though there is a tax treaty that addresses pension schemes nothing in the Treaty overrides the requirement that the distribution must qualify as an “eligible rollover distribution” within the meaning of IRC section 402(c)(4).
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So to clarify, even though the funds could be transferred, it would be considered a taxable distribution by the IRS?