Switzerland US Tax Treaty Update – IRS & Switzerland Info Exhcange
Despite relatively few objections, the U.S. has agreed to ratify changes to the Switzerland and U.S. Tax Treaty (as well as the Japan, Spain, and Luxembourg treaties as well). These changes will generally will make it easier for the IRS to obtain your foreign account and asset information.
Switzerland US Tax Treaty Update
One important aspect of the ratification, is the purpose of the update/revision — which is to improve offshore reporting and exchange of information.
The goal of the increased exchange rules is facilitate ongoing compliance for citizens and residents with foreign accounts, assets, investments and income.
Out of IRS Offshore Compliance?
Time is running out for U.S. Persons to get into compliance before it is too late.
Who is a U.S. Person?
Generally, U.S. Person includes:
- U.S. Citizen
- Legal Permanent Resident
- Non-Permanent Resident who meets the Substantial Presence Test.
When are You Too Late for Offshore Disclosure?
It depends, but a few tips to keep in mind:
- IRS can discontinue the program(s) at any time (as it did with OVDP)
- IRS can increase the penalty at any time
- If you are audited (for any reason) you generally lose the right to submit to any voluntary disclosure/tax amnesty program.
Golding & Golding, Board Certified in Tax Law
We have successfully represented clients in more than 1,000 streamlined and voluntary disclosure submissions nationwide and in over 70-different countries.
Golding & Golding is the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.