@fbelle , sorry for the delay -- I was actually looking for you post so I could reply --- just so many others had come in that I lost track of where your post was. Thank you for coming back in --- put it up in the visible window.
There have been many updates etc. to the treaty but what is interesting to me is that article 19.2(a) refers to public fund based pensions/ remuneration being ONLY taxable in distributing country but as an afterthought Article 19.4 allows taxation of Social Security and other public funded pensions to be also taxed by the resident country at no more than 15% tax rate . So this conflict/ carve out may not help your situation.
At the same time and on looking over your timing of entering the USA and getting the GreenCard creates another issue --- Based on (a) 06/xx/24 legal entry in to the USA, (b) Passing SPT in sometime in Nov 2024 and (c) Meeting the GreenCard Test in 11/xx/2024 , your residency start date would be the first day legal presence in the year. Thus since you were a Tax resident from 06/xx/2024 , there is NO Way to exclude this foreign source income from US taxes.
So my conclusion is that you have to recognize the Total Distribution as Pension distribution for US tax Purposes -- the Gross amount. You report this just as if you had received a 1099-R ( not a substitute 1099-R) -- you tell TurboTax you have pension income, do not have EIN of the distribution /administrator, Box 1 has the whole amount of the distribution, Box 2a has the taxable amount ( this should be total distribution LESS any contribution that you had made over the participating years ), Box 2b , check the Box "Total Distribution", Box 7 -- Distribution Code 7 -- Normal.
Then when in "Deductions and Credits" section, select Foreign Tax Credit and follow through with filling out form 1116 --- your Foreign source income is the 1099-R taxable income, and Foreign Taxes Paid is the actual taxes paid to Switzerland.
This path generally implies that you are ignoring article 19 but just using the article 23 .2 ( first sentence ).
Does this make sense ? Is there more I can do for you ?
pk
