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On 14 February 2013, Switzerland and the United States signed the FATCA agreement. Switzerland and the United States have amended on 30 September 2013 the FATCA agreement in line with the new timetable for FATCA implementation by means of an exchange of notes. Swiss financial institutions now have to implement FATCA from 1 July 2014 rather than from 1 January 2014.
With the enactment of the Foreign Account Tax Compliance Act (FATCA), the United States wishes to ensure that all accounts held abroad by US taxpayers can actually be taxed. FATCA is a unilateral set of US regulations that applies worldwide for all countries. It requires foreign financial institutions (FFIs) to enter into an agreement and disclose information on US accounts to the Internal Revenue Service or levy a high tax within that framework.
Financial institutions that do not implement FATCA will lose access to the US capital market and be avoided by FATCA-compliant institutions. FATCA implementation is causing a significant administrative and financial burden for the affected financial institutions worldwide, which can be alleviated by entering into a bilateral agreement with the United States. The United States proposes two models.
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