New U.S-Swiss FATCA IGA Compels Cross-Border Strategy Review

Since July 1, 2014, the U.S has imposed a set of unilateral banking reporting requirements on the international community known as the Foreign Account Tax Compliance Act (FATCA). Broadly, this legislation obliges all foreign financial institutions (FFIs) to disclose the U.S account information of any U.S taxpayers in their system. A full list of FFIs is maintained on the IRS website.

The objective of the legislation is to inhibit U.S tax evasion practices such as the storage of wealth in offshore accounts. However, the objective has historically faced implementation hurdles from both FFIs and U.S taxpayers who hold foreign ...