US asks Switzerland to disclose FATCA non-compliers’ account details

On December 1, the Swiss Fedral Tax Administration (SFTA) acting on behalf of the American Internal Revenue Service (IRS), asked twelve Swiss banks and one fiduciary to provide data on certain of their American account-holders, as required by the Foreign Account Tax Compliance Act (FATCA).

The information requested by the IRS concerns both American-owned accounts, and accounts of non-participating financial institutions (FIs) to which foreign reportable amounts had been paid, but for which such transactions were not given consent for reporting to the IRS. In this last scenario, the FI involved could report to the IRS only the aggregated information of the accounts.

The US persons and non-participating FIs concerned are required to give the SFTA their Swiss address, or, if domiciled abroad, designate a person in Switzerland authorised to receive the notification. Legal successors of deceased accountholders must also submit a certificate of inheritance.

The deadline for these subjects to provide the requested information or to object to it is December 20 (twenty days from the date of the notification), following this date, the SFTA will issue a final decree for each account relationship concerned by a request.