Suppose that you have an undisclosed offshore account with XYZ Bank, a Swiss bank. You received a declaration of consent from XYZ Bank requesting your consent to disclose your account information to the IRS directly. You refused.
Because you did not consent, your account became subject to aggregate reporting by XYZ Bank. Pursuant to the Swiss-U.S. FATCA Agreement, Swiss banks must report the number of accounts they hold for which the account holders have not given their consent, as well as the total value of such accounts, without disclosing the names of the account holders. This aggregate reporting procedure is complemented by an exchange of information upon request based on the Swiss-U.S. double taxation treaty. Read More
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