An IRS discrepancy means the amount owed

IR 0.672.933.61 Agreement between the Swiss Confederation and the United States of America for the Avoidance of Double Taxation in the Field of Taxes on Income - Concluded on October 2, 1996 Approved by the Federal Assembly on October 10, 1997 Instruments of ratification exchanged on December 19, 1997 In Entered into force on December 19, 1997
DBA-USA Art. 26 Exchange of information1   The competent authorities of the Contracting States shall exchange information that may be relevant to the implementation of this Agreement or to the application or enforcement of domestic law relating to the taxes covered by the Agreement, provided that the taxation corresponding to this law does not contradict the Agreement. The exchange of information is not restricted by Article 1.2   All information that a Contracting State has received in accordance with paragraph 1 must be kept confidential as is the information obtained on the basis of the domestic law of that State and may only be made available to those persons or authorities (including the courts and administrative authorities) who are responsible for the application , Assessment or collection, with enforcement or prosecution or with the decision of legal remedies with regard to taxes within the meaning of paragraph 1 or with the supervision of these functions. These persons or authorities may only use the information for these purposes. You may disclose the information in a public court proceeding or in a court decision. Notwithstanding the foregoing provisions, a Contracting State may use the information received for other purposes if such information may be used for such other purposes under the laws of both countries and the 3   Paragraphs 1 and 2 shall not be construed as obliging a Contracting State to:a To carry out administrative measures that deviate from the laws and administrative practice of this or the other contracting state;b To provide information that cannot be obtained under the laws or in the usual administrative procedures of this or the other contracting state;c To provide information that would disclose a trade, business, industrial, commercial or professional secret or trade process, or the disclosure of which would be contrary to public policy.4   If a contracting state requests information in accordance with this article, the other contracting state shall use the options available to it to obtain the requested information, even if this other state does not need this information for its own tax purposes. The obligation contained in the preceding sentence is subject to the limitations of paragraph 3, but these are not to be interpreted in such a way that a Contracting State can refuse to provide information only because it does not need it for domestic purposes.5   In no event shall paragraph 3 be interpreted as permitting a State Party to refuse to provide information solely because the information is in the possession of a bank, other financial institution, agent, agent or trustee, or because it relates to interests in relate to a person. Notwithstanding paragraph 3 or contrary provisions of domestic law, the tax authorities of the requested Contracting State have the power, insofar as this is necessary for the fulfillment of the obligations under this paragraph, to enforce the disclosure of the information referred to in this paragraph.