I just came across this article http://blog.kpmg.ch/financial-services/switzerland-is-moving-towards-fatca-implementation/, I don’t recall if anyone has brought this particular article yet, but I wanted to share my thoughts on it for comment.
What I find most interesting is the following, suggesting that the banks do not need to be cancelling or refusing accounts of recalcitrants (as I have argued following my posting of the 21 June Swiss Confederation press release):
Implications for insurance companies
The issue around exiting recalcitrant account holders (i.e. a cancelation of a life insurance policy is not possible) seems now to be addressed. However, Insurance companies might now be faced with group requests under the “administrative assistance” (Amtshilfe) and need to prepare for that accordingly.Implications for banks
Similar to the insurance companies neither an exit of a recalcitrant account holder nor the withholding on proceeds is anymore required. However, Banks will as well potentially face more group requests under the “administrative assistance”. The introduction of a layer of countries that are now entering into intergovernmental agreements will add another category of FFI’s, which in practice will increase the complexity for implementation…
I got a letter in the mail from the IRS stating that a request for transcript of tax return could not be processed because of my address across the sea. So, I called to correct the address, corrected it and then later got another letter from the IRS stating that my non-US address still didn’t match their records, which is still the case today.
