The aim is to achieve improvements such as reducing the withholding tax on dividends from qualified investments to 0% (zero rate). It can be concluded that the ratification of the Amending Protocol will now allow the start of these ongoing renegotiations. As far as the United States is concerned, in addition to the DBA provision on the exchange of information, other rules must be observed when it comes to transmitting information in the field of taxation. It is therefore worth taking a closer look at them. On January 1, 2017, U.S. regulations under Section 871(m) came into effect. The 871(m) scheme aims to regulate derivative instruments such as futures, forwards, full return swaps, stock lending and repo transactions by referring to US equities, regardless of where the issuer is located. A reporting Swiss IF must register with the IRS and enter into an FFI agreement with the IRS. . . .