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If client is receiving pay. from her dead husband's soc. sec. account in Switzerland can I treat those pay. the same as her soc sec pay. from her U S soc sec account?
My client is U.S. citizen living in U.S.
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No, you can't apply the same rule as with US social security benefits because foreign benefits are not within the definitions of §86(d).
Foreign social security benefits are taxable as annuities unless specifically provided for by an income tax treaty. Since Article 19(4) of the US-Switzerland income tax treaty does not include any special provision, the general tax treatment will apply.
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