Final regulations reducing burden under QI & FATCA

On 27 December 2019, the U.S. Department of Treasury and the U.S. Internal Revenue Service IRS released final regulations under chapter 4 (FATCA) and chapter 3 (QI) providing burden relief under QI & FATCA.

New ruling on perceived dividend stripping and stock lending transactions

On 16 December 2019, the Swiss Federal Supreme Court ruled on a case concerning perceived dividend stripping transactions. Similarly to previous rulings, the Court once again rejected the refund of Swiss withholding tax.

Recent QI, FATCA & Section 871(m) updates

Jason Zücker summarizes the key points and comments on the implications for Swiss financial institutions (SFI) to shed some light on the latest updates regarding Section 871(m) and the QI/FATCA regimes.

32nd Annual Forum of the International Tax Information Reporting and Withholding Conference

The 32nd Annual International Tax Withholding and Information Reporting Conference was held in New York City on November 14–15, 2019. This forum offered industry professionals the chance to interact directly with counterparts at other financial institutions and with the U.S. Internal Revenue Service (IRS) on recent developments impacting withholding and report […]

Protocol to the Swiss-U.S. Double Tax Treaty – latest developments

Further to our Newsletter of 10 July 2019 (see attached), Switzerland and the U.S. have exchanged the instruments of ratification of the Protocol to the Swiss-U.S. Double Tax Treaty (DTT), which has entered into force with effect from 20 September 2019. This has the following key implications for Swiss Financial Institutions (SFI).

Protocol to the Swiss-U.S. Double Tax Treaty

After being blocked for a decade, the 2009 Protocol to amend the Swiss-U.S. Double Tax Treaty (“Treaty”) is likely to be subject to a vote in the U.S. Senate during August. Read about the key consequences for Swiss Financial Institutions (“SFI”) in this article.