non-consenting account tax.

[Анна Ф]

non-consenting account

[leka11]

Consent of Account Holders and Reporting Requirements
The consent given by a US account holder will apply irrevocably to the current calendar year and automatically be renewed for each successive calendar year, unless it is revoked by the account holder before January of such year. Lacking the consent of the account holder, a Swiss financial institution cannot report a US account directly to the IRS. The consequences of refusing to consent, however, include aggregate reporting by the respective Swiss financial institution, an IRS group request to the Foreign Tax Authority (“FTA”), transmission by the Swiss financial institutions of the account information to the FTA, and exchange of such information by the FTA with the IRS. The FATCA Agreement requires that Swiss financial institutions report the aggregate number of US accounts and their value by January 31 of the following year (i.e. within a month of year end), regardless of the other timing requirements for aggregate reporting set forth in the FATCA Agreement and the Final Regulations. With respect to non-consenting US account holders, Swiss financial institutions will need to track US account balances in a way that permits reporting shortly after the close of each year. For new accounts opened after December 31, 2013, that are identified as US accounts, obtaining a consent consistent with the terms of an FFI Agreement will be required as a condition to open the account.