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Switzerland in the age of automatic exchange of banking information (swissinfo.ch)
133 points by baazaar on Sept 18, 2019 | hide | past | favorite | 147 comments



To me as a Swiss citizen, born in Switzerland, living in Switzerland, it's an impertinence that every time I open a bank account with a Swiss bank I have to fill out at least 1 form with information about my relation to the US, about my travels in the US and whether I might have to pay taxes there.

As a side note, the only other country besides the US that collects taxes based on citizenship and not based on residence is Eritrea. The tax policy of Eritrea is described as extortion by a lot of western governments and media.


For myself (a US citizen living abroad), my biggest annoyance isn't that I'm taxed on my income overseas, it's that it effectively is taxation without representation.

Even though I'm paying tax overseas, there's no US Representative who fights for my interests. I have one who fights for the interests of the residents of a district I lived in years ago, but I have no relation to that anymore. I have a US senator who fights for the interest of the state listed on my old drivers license, but none who represent me as an expat.

The US was founded precisely because those who were living overseas had no representative fighting for their rights, yet they were still taxed. The same thing is happening today. What I want isn't for this tax to stop, it's to have representation.


Do representatives really and honestly fight for the interests of their constituents or do they simply vote in ideological buckets. Dems with dems and repubs with repubs regardless of where you are? The local interests seem to be subservient to national goals at the federal level. I have yet to see our representatives really fighting for your interests. I'm not seeing much evidence of representative democracy but rather tribal thinking.


They do more than in other countries. Representatives have autonomy to vote as they see fit, without being beholden to the party line, for instance they can vote with their caucus [1].

This is in stark difference to countries like the UK, where MPs have to vote on the party line unless it's declared a conscience vote by the party leader [2]. Voting across party lines in Westminster system parliaments will get you kicked out of the party.

[1] https://en.wikipedia.org/wiki/Congressional_caucus

[2] https://en.wikipedia.org/wiki/Conscience_vote


That's not entirely true. Having the Whip removed was a very unusual move by PM Johnson, which is why it gained so much attention. The US Congress is based on the Westminster system. In effect, MPs are allowed to vote however they feel, but there can be consequences to them voting against the party line.

Which is also the case in the US, the party could run a primary challenger to them in the next election.

It's the same case in most parliamentary systems, it's usually right of MPs guaranteed in a constitution. Tradition and procedures, however, tend to ensure party line votes, but there are no legal ramifications, if an MP rebels against the party line.


In France we have representation for citizens living abroad since 2012:

https://en.wikipedia.org/wiki/Constituencies_for_French_resi...

"The constituencies for French residents overseas are eleven French constituencies, each electing one representative to the National Assembly."


My first thought was "wow, it would be cool if we had something like this in the US". But after a second, I realized that probably many people in the US are so rabidly nationalistic that if this were ever proposed, they would be against it, because "if you don't want to live in our great country, why do you deserve representation?" It's sad, really.


I’m not entirely convinced it’s fair for non residents to vote, especially those that have no intentions of coming back.

Election results for French expats are typically very different from those back home. LePen was not even close to be qualified for a second turn in the last presidential elections in London. Unless you live in France you would typically not be subject to any of the laws the new government would enact, so part of me thinks “why should I have a say in this?”

On the other hand, LePen proposed to strip French expats of their citizenship if they hold other nationalities, so I suppose having a say in the matter was only fair.


I'm totally fine with not voting at the state level. I don't think it makes any sense that I can vote in a state I don't live in, just because it was the last one I lived in before I left the country.

But if they're taxing me, I deserve a vote at the federal level 100%.


>I’m not entirely convinced it’s fair for non residents to vote, especially those that have no intentions of coming back

I think it would be fair to be able to opt out of tax filing obligations in the US and for that give up the right to vote until you return.


You are assuming all French nationals abroad have no intention of ever moving back to France. This is certainly true for a fraction of them but that’s only going to be a fraction.


I disagree incredibly strongly with this idea - I'm Polish and Poland wasn't even on the map of the world for over a 100 years, yet the country survived. Then again during the communist rule we had a proxy government formed in London. Polish expats living abroad are definitely still Poles and as a nation we have a history of those people carrying what made our nation come back from the brink of destruction over and over again - the idea that as a Pole living abroad you couldn't vote is almost repulsive to me.


I am also a US citizen abroad and I don't understand your annoyance. This is exactly why Foreign Earned Income Exclusion exists. For anyone not aware you don't pay taxes on 100k if you are out of the USA 330 days out of the year. 200k if you are married.

Do you qualify? Then you are exempt from such a ridiculous amount that it is hard to argue this.

Or maybe you visit the USA too much to qualify? In which case you do have enough ties that I think tax makes sense.


I'm married to a US citizen. My children have inherited US citizenship via this route. We have to spend thousands preparing tax returns reporting no income each year for three people (the children have bank accounts).

  If you buy a house, things are going to be complicated.
  If you have a workplace pension from your job, you're probably screwed. State pensions have screwed people too.
  If you invest in stocks, or mutual funds, you'll pay more in tax preparation than you'll make.
  If you set up your own company and are not paid as an employee but as the owner, you will be screwed.
  Rent out a property, screwed.
  Fail to declare every account that you're a signatory on? Prepare to pay up to 125% of the contents. 
  If you're children are beneficiaries of a trust set up by their non-american grand-parents? Totally screwed.
Almost every American expat I've spoken to has had a shock when they find they totally didn't understand their commitments. The only ones who didn't were employees of big banks/hedge funds whose employers paid a big 4 accountant to take care of everything.


I do understand the annoyance. The $100k exclusion, as others have mentioned, is not a "ridiculous amount", it's all relative to where you live and how much you earn.

You might also think it is "ridiculous" because you only earn money from a paycheck (e.g. you are an employee). For the self-employed things look very different: your revenue might easily be $200k, while your actual income is half that. Your foreign business pays taxes on income, but claiming the same deductions in the US might be difficult or impossible, so you might end up paying taxes on your $200k of revenue.

More importantly, though, the amount of paperwork that the US requires (FATCA and FBAR reporting) is ridiculous. And preparing your US taxes if you are an expat is a minefield, there is no way you can do it yourself. You need help from experienced tax accountants. All in all, it is a significant burden.


I will probably give up my USA citizenship at some point because of this.


I suggest not admitting this publicly.


I'm curious: why?


My concern originates with this statement [1]:

> If the Department of Homeland Security determines that the renunciation is motivated by tax avoidance purposes, the individual will be found inadmissible to the United States under Section 212(a)(10)(E) of the Immigration and Nationality Act (8 U.S.C. 1182(a)(10)(E)), as amended.

[1] https://travel.state.gov/content/travel/en/legal/travel-lega...


It's much more complicated than just having a foreign income exclusion and being out of the country.

If your income is above $100k, you also have to fill out the AMT worksheet, which may result in you needing to calculate everything to deduct the foreign taxes you've paid.

If you have US stocks and sell them, you have to worry about paying capital gains taxes to the US (they consider this US income, regardless of if you received the stocks as part of your employment), and you generally have to pay taxes to the country you're living in for that as well. If you're lucky you might be able to deduct the US taxes or expected taxes, otherwise you might not be able to do so or might not be able to do so until the next year.

You also have to report your overseas accounts every year.

When I first moved overseas, yes, it was pretty simple to just fill out my 1040 and my form 2555. Last year I needed those plus the 1040 Schedule B and form 1116. Next year things will get even more complicated since this year I bought an apartment, so there's a mixture of rent deduction and mortgage deductions, plus a significant capital gains tax burden due to selling stocks for my down-payment on the apartment.


It's still a lot of paperwork to file, just to get told you don't have to pay anything. And that's paperwork in addition to the paperwork you have to file in the country where you are earning your money.

Though, I am curious, since my wife is a US citizen, and we are living in my home country; does the 200k if married limit count, if your spouse is a foreign citizen (like say, me)?


By the way 100k may seems a lot, but not in Switzerland where the median salary is at 80k$ per year. It means that if you are in a senior position you will make easily more than 100k... For that simple reason I personally know at least 3 ex US citizen that all renounced their citizenship (often painfully because of the paperwork involved).


Just because I have a discount on my taxes (which is fair considering I don't use roads, public utilities, law enforcement services, emergency services, medicaid, or qualify for contributions towards my social security points) doesn't mean I don't deserve representation for the amount I pay over that discount.


I am a Dane living abroad. I don’t have to do any paperwork and jump through hoops for the Danish government.

That the U.S. government makes demands of people living outside its borders is preposterous.


There are enough US citizens abroad to justify about 7 or 8 members of the House of Representatives, but how would you allocate them?

There are enough in Mexico, and enough in Canada, and maybe enough in the Philippines to have one Representative for each of those.

The rest, though, are sufficiently spread out that when you group enough different countries together to get enough US citizens for a Representative, that Representative will have such a diverse group of constituents with such diverse concerns that it is not clear the Representative could actually effectively represent them.


Maybe just allocate them through proportional representation?

Seems like that would pretty much fit the problem of representing diverse sub-groups naturally. For example say the demographic of "student-age backpackers teaching English overseas" was about 20% of the expat population. Then all else being equal you'd expect candidates who best represented this group to garner about 20% of the vote totals, and therefore gain 1-2 seats.


Maybe the US could look to France again - since they do just this in their National Assembly, and also have representatives for citizens aboard in the Senate https://en.m.wikipedia.org/wiki/Constituencies_for_French_re...


Maybe France could not look at the US and also start taxing citizens everywhere in the world: https://www.google.com/amp/s/www.boursorama.com/actualite-ec... (french source)


That’s pretty bad, you could end up with two countries claiming you are fiscally resident in their country at the same time.

France has actually considered taxing French citizens abroad like the US. It comes regularly during presidential campaigns. I think the last serious attempt was Hollande. They backed down because it would require to renegotiate every tax treaty and they didn’t want to open that door.

But I think it will happen one day.


This is an interesting point. Can you vote in elections at all? I'm curious as to the nature of the representation you desire. Would there be some kind of "expat" state with senators and representatives? How would this compare to the representation of territories like Puerto Rico?


>represent me as an expat.

Immigrant is not a dirty word


Nobody implied this.

All immigrants are expatriates, but not all expatriates are immigrants.

The term immigrant denotes someone who has left their native land permanently - that is, they never plan on moving back there. Many expatriates do plan on returning home, so calling them immigrants is inaccurate.

Please understand that anyone studying abroad, stationed overseas (either with the government or military), or working abroad is an expatriate - no matter where they're from and where they're living.


Isn't it the wrong word, though? From the US perspective (which is what's relevant here), he's not an immigrant.


Emigrant is the word you're looking for, since we're talking about the policies country towards someone who left it.


You're an emigrant if you left permanently, otherwise expatriate is still the correct term.


There’s a very active association of French people with US nationality - because they were born on US soil, but moved back to France soon after, in some cases because their parents were briefly working there, or on vacation and thought it’d be nice for their kid to have the US nationality - advocating against this.

“The association of Accidental Americans”:

https://www.americains-accidentels.fr/


The US tax comes from the Union in the Civil War. Fearing their wealthy base would flee to Europe to dodge Civil War tax hikes, they passed the citizenship based tax to ensure the war could continue to be funded.

Of course once a government adds a tax it's very hard to eliminate it, so here I am still paying a Civil War tax, an American living in Switzerland.


As an American citizen living in Switzerland, it's somewhat of an impertinence that I'm essentially limited to using one bank - Post Finance - when Germany and a number of other countries with large expat populations here now ask for and receive the same information on their citizens.

Edit: I also want to add that you're referring to income taxes. Several European countries collect wealth tax on global assets.


As a Swiss citizen who immigrated to the USA to study, it's an impertinence that I had to lose all my Swiss bank accounts because they found out I had touched the tainted land and I was no longer worth keeping as a customer.

Jokes aside, I totally understand why after the botched 2009 issue, Swiss banks just don't want to deal with Americans. We got screwed hard by the DOJ, and were bullied into going against our core principles. I don't have a lot of empathy for Americans not being able to get Swiss bank accounts after the USA fucked us over like that.


> I don't have a lot of empathy for Americans not being able to get Swiss bank accounts after the USA fucked us over like that.

Why not? We don't blame the Swiss for this. This is clearly the fault of the US government and I think we can have sympathy with each other for being screwed over by one of the most powerful organizations on the planet.


> limited to using one bank

An easy solution is to trade your US citizenship to a Swiss one. It takes just 5 years on permit C.

> Several European countries collect wealth tax on global assets.

Including Switzerland.


> It takes just 5 years on permit C

This is accurate, however, you need to spend at least 5 years in Switzerland to apply for a C permit and have been resident a minimum of 10 years in Switzerland in total, including the last 5 continuously. You'll also need to meet minimum cantonal and communal residency requirements, so if you move canton or even communue at 9 years 11 months, you'll probably have to wait another few years. The process itself will take a few years also.

After all that, you are still defined as a "US Person" for tax purposes and thus banks are required to disclose your information to the US. US Persons are any person with tax liability to the US. You're tax-liable as a citizen (also as a green card holder or possibly a married partner of a US citizen). So having spend 12-13 years minimum in Switzerland to get a passport, you then have to give up your US passport, which will take time and is also permanent.

Usually it doesn't take 12-13 years minimum with stringent residency requirements and the requirement to learn a foreign language to open a bank account ;)

All that said, it is my understanding that the PostFinance-only thing was a reaction to the Credit Suisse fine from 2014. After that, Swiss banks closed accounts and mortgages of Americans without warning as a way to avoid any future risk - a bit extreme, but they were in a legal pickle: Swiss law prohibits them from disclosing account information to anyone not at the bank and includes custodial sentences for the disclosing employee. There was thus no mechanism for disclosure to the US that was actually (at the time) legal in Switzerland. This has been remedied. Banking secrecy still exists, but banks are allowed to transfer information to the Confederation (Swiss Federal Government) and the Confederation can of course then transmit it onward to the relevant parties.

Even more bizarrely, the whole FATCA issue was mostly about wealthy US residents using offshore tax havens to avoid taxes, not your average expat who simply wants a bank account.

I believe that US expats can now open accounts at Swiss banks other than PostFinance again, although I caveat that statement by saying I'm not a US person.


It's between 10 and 11 years rather than 12-13, but, regardless of that, I was still just making a joke.


Definitely understand that it feels like a slap in the face given Switzerland's tradition of bank secrecy, but the reason these (multinational) banks now do this is that, generally speaking, they and their customers are paying a modest inconvenience for their past criminal actions. These banks are not solely Swiss; they are multinational corporations and were probably breaking the law. Maybe not Swiss law, but the law of countries they had a nexus with.

https://en.wikipedia.org/wiki/UBS_tax_evasion_controversies

https://www.accountingtoday.com/articles/a-top-swiss-bank-se...

https://www.independent.co.uk/news/business/news/swiss-bank-...

https://www.channelnewsasia.com/news/commentary/1mdb-najib-r...


> US that collects taxes based on citizenship and not based on residence is Eritrea

I believe Japan also does that, for a few years now.


No Japan does not tax Japanese citizens with foreign residency. They did start an exit tax for departing Japan residents to discourage this.

Japanese tax residency has a slippery legal definition, tax residency begins the day after you enter the country “for a purpose exceeding one year” (as determined by the tax authorities not you). So they do often challenge foreign residency claims.


Swiss banks are in that position today because some of them engaged in criminal conspiracies to help US customers commit tax fraud. If they want to participate in the US financial system then they have to play by US rules.

US citizens residing in other countries can still receive some services and protection from the US federal government. So it's completely fair to tax them for that. We can argue about the value of those services but clearly it's >0. Those who don't like the deal are free to pay an administrative fee and renounce their citizenship.


Every single bank in every country that wishes to use USD is in that position today, it is not related to whether they were shown to help in some criminal activity.

> US citizens residing in other countries can still receive some services and protection from the US federal government.

Seriously, like what? In how many percent of situations does this ever come up. Sure it's more than >0, but if it is like 1$/person does it really make sense? This is economic bullying by a country that right now happens to be in a position (having strong military, influence and their currency being the reserve one) to be able to get away with it.


>This is economic bullying by a country that right now happens to be in a position (having strong military, influence and their currency being the reserve one) to be able to get away with it.

I wonder if this is the kind of stuff that pushes EU politicians forward with their notions that they cannot rely on the US?


For starters the first $103,900 is tax free if you qualify and are living abroad.

What it comes down to is that because of its size and economic power there is an enormous incentive for wealthy people who earn their income (in an actual sense, not a tax law menagerie sense) in the US to try to avoid US taxes by living abroad and moving assets, their "home", etc outside of US jurisdiction while still in reality earning their income from the US.

One of the basic benefits is always being able to return to the US. Being inside American borders is very much safer than being anywhere else if/when the next major global military issue arises.

You also get the benefits of the US legal system if you maintain ties, investments, etc.

If you don't want to pay those taxes you are welcome to renounce your citizenship, but you have to get another country to accept you first. (they won't revoke your citizenship if the result is your being stateless)


> One of the basic benefits is always being able to return to the US. Being inside American borders is very much safer than being anywhere else if/when the next major global military issue arises.

It’s a funny fear, because today, being in the US vs. some other developed country takes about 7-8 years off your life.

Meanwhile, those developed countries with functioning health care systems that you can return to whenever don’t bother with worldwide taxation.


>It’s a funny fear, because today, being in the US vs. some other developed country takes about 7-8 years off your life.

https://en.wikipedia.org/wiki/List_of_countries_by_life_expe...

When accounting for all sexes, US sits at 79.3 years and the top country sits at 83.7 years. Where is this "7-8 years" coming from?


> Where is this "7-8 years" coming from?

My poor recall.


The factors which shorten average lifespans for Americans by a few years relative to some other developed countries are almost entirely lifestyle issues. They aren't actually caused by geographic location or government problems.


I think that’s debatable. France for example goes to great lengths to preserve local food culture and the protection of locally produced heirloom foods.

The US government couldn’t care less. If everyone decided to eat only TV dinners and shelf stable snacks that would be A-OK, even desirable because that kind of thing leads to GDP growth. France would never allow it.

US governments are borderline contemptuous of tradition, and tend to court radical reinventions of basic needs. That leads to people getting hurt, but is great for the economy.


>If everyone decided to eat only TV dinners and shelf stable snacks that would be A-OK

>France would never allow it.

While I do not support eating unhealthy foods like that on a regular basis at all (I have some sort of instinctive repulsion towards that), I do support allowing adults to have the freedom to make their own choices regarding what they eat.


By and large, American grocers don’t sell food like that, so we don’t really have the choice.

In the U.S. no one is going to force you to buy anything, but no one will save you when your market disappears.

It’s a kind of freedom, but it’s not “more choice”. It’s often less choice.


>It’s a funny fear, because today, being in the US vs. some other developed country takes about 7-8 years off your life.

Does it actually?

I assume that disparity is more to do with the populations of impoverished people around this very diverse country that can't compare to smaller European countries that just don't have those populations.

There is no Mississippi in Germany, those populations are in other countries.

If you compare the whole European Union to the US the disparity is much smaller.

>It’s a funny fear, because today, being in the US vs. some other developed country takes about 7-8 years off your life.

I think that is an exaggeration, I can't find that statistic anywhere.

But you have to look at people in your demographic, not the entire country.

The US has the best health care in the world if you can afford it.

Just about anybody can get insurance and set aside the max out of pocket costs to insure themselves and their family, but they will take a considerable hit in quality of life, home size, luxuries, etc. In other countries that health care is paid for with lowered salaries through taxes and quality of life takes a hit anyway.


There are plenty of large European countries with good healthcare systems: Germany, France and the UK, for example. I don't think there's a reason why countries with 60-80 million residents can establish good healthcare systems, but countries with 300 million people can't (even China, a much larger and poorer country than the US, is approaching universal coverage). But even if that were the case, individual US states could step in and set up their own universal healthcare systems.

> There is no Mississippi in Germany, those populations are in other countries.

It depends on what you mean by that comparison. Germany relatively recently absorbed a much poorer East Germany. There are still states like Mecklenburg-Vorpommern that are much poorer than the average in Germany. Yet they're all integrated into Germany's very good healthcare system. It could be the same in the US, but it isn't, for political reasons.

> If you compare the whole European Union to the US the disparity is much smaller.

This is not true. The European Union member states have a much greater range of GDP/capita than US states.


You would have to be very rich indeed to achieve the same level of cover as is provided in comparable economies (UK/DE/AU etc), because the insurance is expensive and out of pocket costs / copay is high, and you may discover you cannot get or maintain insurance once you develop a chronic condition.

But even if you dealt with a broker and crafted a special insurance insurance product to deal with the eventuality of being denied further insurance, you are ignoring something significant: you don't improve the quality of life or lifespan of the population by making healthcare only accessible to the rich.


The ACA has removed the pre-existing condition problem, and significantly changed some of the pricing considerations. It’s more affordable now than many are led to believe based on the old structure.


> The US has the best health care in the world if you can afford it

But you don’t need a US passport to access that, just a decent one.


No, the US is likely to be the other side of whatever the next major conflict is. If it's a major conflict it will likely end in nuclear war, even if it doesn't start that way. The US is the last place you want to be. Australia, New Zealand, or South America would be much safer, and the climate still amenable to growing food during the nuclear winter. In Australia and New Zealand the land area to population is also very high, which helps in a famine situation.

I like to think (hope? Dream?) That there won't be any more major conflicts now that we have nuclear weapons. But betting against the stupidity of politicians seems like a risky proposition.


> One of the basic benefits is always being able to return to the US. Being inside American borders is very much safer than being anywhere else if/when the next major global military issue arises.

Well to be fair, once you move back in you will already start paying taxes again. This "benefit" is already paid for by you paing taxes when you effectively become resident again after moving inside the country again. Exactly like it works for any other country right now. This is questionable as a benefit while you're not living there.

> You also get the benefits of the US legal system if you maintain ties, investments, etc.

You get those benefits even if you just do some business in US as a foreigner. By this logic, should US also tax worldwide income of anyone who does any business in it and relies somehow on its legal system? Cmon this is a huge stretch. Also if you maintain ties, investments, this means that you are already helping the country by either supporting business or outright keeping your capital in the country and helping it by investing in it. You are ALREADY helping the country. And by this logic the country is supposed to tax you further to what puniush you for helping it?


The most obvious is something like state department emergency assistance, but there's plenty of US government programs without a residency requirement.

For example: federal student aid doesn't require US residency.

https://studentaid.ed.gov/sa/types/international

Also, the taxes that the US imposes on citizens overseas has some pretty significant exceptions. US citizens can deduct over $100,000 worth of their foreign-earned income and part of their housing expenses.


That’s part of the mess: the US tax system isn’t the same as others’, so you now have to optimize for 2 systems.

Differing rules of what’s a short-term vs long term capital gain.

E.g.: Canada doesn’t tax capital gains on your Primary residence when you sell it, but US does.

And buying a non-US ETF can create another tax mess since you’ve now bought into a multibillion dollar trust that doesn’t file with the US gov.

The US doesn’t see your Canadian Tax-free savings account as tax free, so now you have to keep track of every transaction in there.


The us does not tax capital gains on your primary residence unless you lived in it for less than 2 years.

https://www.investopedia.com/ask/answers/06/capitalgainhomes...


Seems even more complicated than that. It's only on $250k in gains, or $500k if you're a couple filing jointly.

It's a lot of money, but if you bought a house in Canada in Toronto/Vancouver 30 years ago, you'd be paying US CGT on its sale.

And can a US-citizen/non-US-citizen couple still file jointly?


In the US you also got to deduct the interest you paid on your mortgage from your taxable income for 30 years.


I never said our tax code wasn’t complicated. I simply said expatriates still get some services for their tax dollars.

I’ll be first in line to complain about complicated taxes. I file three income tax returns, thanks to the fact I live in a jurisdiction with local income taxes as well as state and federal.


I should think that if you are doing something that every other country in the world (save one[0]) does not do, you might want to at least consider that it just might be wrong, rather than cavalierly dismiss an opposing viewpoint out of hand.

> US citizens residing in other countries can still receive some services and protection from the US federal government.

Same deal for expat citizens of many other countries and their government, but they aren't taxed for it.

There's an expat downthread who was extracted from a dangerous country, and the US later sent him a bill for his services. After reading that, it jogged a memory of reading about this being a common occurrence. So what are these "services" he's supposedly paying taxes for?

> If they want to participate in the US financial system then they have to play by US rules.

This is just simple strong-arm bullying and control-freak data collection, and will almost certainly come back to bite the US as its economy declines over the next decades and loses the leverage to impose these sorts of things.

(Disclosure: I'm a US citizen who resides in the US, and think these regressive practices are gross.)

[0] Eritrea, which is not exactly the best company to be in with regard to this topic, since if you are an expat and don't pay taxes, they threaten your remaining family with violence until you pay. And that's just for a 2% flat tax.


Swiss banking history and the process they and their US customers have to go through are entirely unrelated. The US simply created these regulations because for some strange reason the US believes it somehow has the authority to collect every last penny on every single citizen regardless of residence and or if that person gets any value out of having said citizenship. Something the rest of the world obviously doesn’t agree with.


Swiss banks were doing business in the US, setting up offices in the US, and literally counseling American clients on how to export their assets. These were Americans living in America doing business with Swiss banks on American soil in order to avoid taxes.

Several banks have been stomped on for this behavior, the "oldest bank in the world" closed as a result and there have been many other actions.

If you don't want to deal with American taxes, renounce your citizenship, or earn less than $100k abroad.


Correlation =/= Causation

There are way bigger fish for the US to fry other than Switzerland. FATCA wasn’t created because of Swiss banks. Claiming otherwise is ignorant.


For many decades Switzerland was definitely the biggest fish to fry for most western countries regarding offshore accounts and tax dodging. By far.


There are but the prosecutors went for the biggest win, not the biggest target.

Making cases is hard because these things are very convoluted.

Swiss banks, however, were doing things which were really obviously illegal and their brazen tax avoidance made them a good target for prosecutors. Other targets are honestly just better at avoiding the law and will be harder to get to. Progress is being made though.


That's true, but has nothing to do with the mess US citizens have to go through, when opening a bank account abroad.

A lot of banks in Switzerland will outright refuse to deal with US customers, even when they have residency.

This is, however, not specific to Swiss banks. US citizens (or even green card holders) can have a hard time opening a bank account just about anywhere, because of such onerous reporting requirements[1] to the US authoritues that's it's just not worth their while.

[1] https://en.wikipedia.org/wiki/Foreign_Account_Tax_Compliance...


> We can argue about the value of those services but clearly it's >0.

From personal experience, I can tell you that (value of expatriate services) - (cost of dealing with US tax system) is a very deep negative value.


I assume you've never been in a foreign country when it fell apart and the US government had to evacuate their citizens. Some other expatriates weren't so lucky.


I have, actually (Kenya). I'm also lucky enough to hold the passport of another developed country that helps its expatriates and doesn't have a regressive expatriate tax system, so I can compare.


I need to add that a country providing expatriate safety services has nothing to do with a tax system and everything to do with supporting the country's imperialist interests.

It's much harder to get your citizens to work in your interest in risky foreign countries if you aren't willing to back them up.


Fun fact: if evacuated in the manner you describe and as a civilian, you get a bill for it.


I really doubt this is a major worry for a tax exile living in Monaco.


Most countries do the far more reasonable procedure of having you give up ties and get another residency, rather than fully renounce.

Getting a second passport is extremely costly in terms of time or money, and your “free to pay an administrative fee and renounce” comment indicates that you don’t understand this at all.

Source: went through the process of acquiring a second passport for the purpose of renouncing.


The only "services and protection" you receive from the US government abroad are pretty much consular visits if you're arrested. Everything else you pay for, normal in advance, although repatriation is usually billed after the fact.

The US rules apply not just to Swiss banks, but to all banks. Many overseas banks will no longer allow US citizens to open accounts, and some have even closed accounts rather than deal with the burden that the US is placing on them. This does not help US citizens at all.

You cannot just renounce your citizenship. Beyond it being costly, you have to have a second citizenship first, which takes time - 7 years is a common length of time, although some countries have shorter or longer requirements, and many have language requirements that you're expected to meet.

The US is one of two countries in the world that require you to jump through tax hoops if you're working overseas.


> Swiss banks are in that position today because

uh no.

Every bank around the world is in that position today because of the FATCA treaty.


You know there are people who are citizens that have never been to the US. Why should they have to pay to renounce citizenship? If $Forefathers_nationality told you that you were a citizen and that you'd have to pay taxes, how would you feel about that?

Then there's Boris Johnson, British PM, and until recently US citizen. What benefits do you think he would have been getting as a US citizen abroad, over and above diplomatic protections he already had as MP and member of Govt?


Multi-citizenship is a very strange concept anyway. Sure you can check the boxes and countries A and B consider you a citizen, but it's bizarre to me that one nation would let you swear loyalty to another without revoking your citizenship. The naturalization oath of allegiance, at least the American one, is very explicit about conflicts of interest like that but we've just sort of chosen not to enforce those parts of it.


Citizenship is a very strange concept to me. The fact of a person being born in a specific geographic location giving the surrounding nation-state the right to claim some sort of perpetual jurisdiction over that person to the exclusion of all other nation-states seems, upon reflection, quite bizarre.


Correct me if I'm wrong, but I believe most Western democracies freely allow people to renounce their citizenship.


Not if it will result in you becoming stateless.


This is not particular to Switzerland. Any bank in any country that has U.S.-related clients (just having a green card is enough) is compelled by the U.S. to comply with FATCA and similar legislation.


USA is overreaching, European countries should stand up this crap. I'm a Polish and US Citizen and I remember a situation where I was at an airport in Poland and was not let onto a flight after presenting a valid US passport and Polish ID card to the Polish border patrol. They didn't allow me onto my flight due to lack of a Polish passport (Polish law says I need a Polish passport when travelling to the US). I called the US embassy which told me they couldn't help me because I was Polish citizen on Polish soil. In that case why should I pay taxes while abroad? Will the US come to my rescue if a war broke out or major disaster occurred? They couldn't even get me onto a flight back to the US.

I ended up getting a hotel for the night, bought a plane ticket to Germany the next day and another one from Germany to the US. I was offered a small refund for my round trip tickets from Poland to the US. Only person I could count on was myself that day.


> USA is overreaching, European countries should stand up this crap. [Recounts story about issues at Polish border due to Polish law and Polish citizenship.]

So you would have liked the US to stand against Polish crap on your behalf?


I pay Polish taxes on the money I earn in Poland and I abide by Polish law while in Poland, why should I abide by US law while in Poland? What's the benefit to me? I mean if I'm paying an overreaching tax then yeah I kind of expect them to overreach for me.


> (Polish law says I need a Polish passport when travelling to the US)

What would you have expected the US to do? Smuggle you out of the country?


Honestly, one call from the embassy and I would have been on that flight, believe me.


As far as I understand, if you were trying to fly from the US to Poland using a Polish passport you would have faced the same problem (or even worse, as you wouldn’t have had a legal way to exit the US at all without a passport).


I think he expected US consular services to fix his passport problem. After all, if hes paying taxes solely for consular services, and he is not getting that assistance, then it begs the question, why is he being taxed in the first olace if there are no benefits whatsovmever?


His “passport problem” was not having a Polish passport when Polish law requires Polish nationals to use one to enter and exit Poland (at least through non-EU borders, I guess). Not something the US consulate can help with, probably.


It's the rule of master nationality. If you are in a country which you are a citizen of, that country may treat you as only a citizen of that country. That means you cannot be American in Poland. You are Polish and you may not leave without a passport.

This is the only reason dual nationality is tolerated in the first place. Otherwise every dual citizen is a walking diplomatic disaster waiting to happen.


Not really sure what you would have expected the embassy to do in that case? In Poland, Polish law applies to everyone, U.S. citizen or not.


Just because something is the law doesn't mean it has to make sense or be justifiable. It was a frustrating situation to be in, I had evidence of being a citizen of both countries and despite that was not allowed to travel freely between them. I expected the USA and Poland to help me not fight me that day especially since I had done nothing wrong.


I am no expert, it would be great to read it from someone with knowledge in this field.

What if a shell corp is created in a country that is not included in the list of the ownership info automatic exchange? Instead of option A, someone could go with option B and would be fully protected:

Option A: Owner in the UK -> Swiss Bank account

Option B: Owner in the UK -> Shell corp & legal entity in a country not included in that list -> Swiss Bank account not on the name of the owner, but held by the shell corp/legal entity


That's where the concept of UBO comes in - the reporting party is supposed to trace this through to the ultimate beneficial owner. And if they can't then they're not supposed to accept the business (KYC fail).

https://en.wikipedia.org/wiki/Beneficial_ownership

A lot of the offshore locations a laymen can name report this stuff anyway (to varying degrees of course).

The whole straight up hiding money approach(Or to put it in hn terms "security through obscurity") isn't really a thing anymore.


Note that this only applies to banking. Assets "directly held" (eg fine art) are exempt from eg FACTA. A loophole big enough to drive a truck through, but only for the wealthy...


Interesting - didn't know that


Wasn’t there an article recently describing how you can register a company in UK through a web portal and put absolute rubbish in a UBO field without having to submit any single piece of documentary evidence?


I think you're looking for this one[1]

The UK, with their channel islands (and the BVI) are one of the biggest hypcrits when it comes to finger pointing regarding support of tax dodgers and plutocrats hiding their ill gotten gains.

Another convenient vehicle to hyde (pun intended) your dirty money is real estate via a shell company in the UK, mostly in London[2]

[1] https://www.theguardian.com/world/2019/jul/05/how-britain-ca...

[2] https://www.vanityfair.com/style/society/2013/04/mysterious-...


No idea what UK company registration processes look like.

Possibly. You're not gonna get far moving your mountain of coin without the help of lawyers, accountants, investment bankers, banks, prime brokers etc.

...none of whom will touch you if you can't prove this stuff reasonably well.

As for people submitting straight up fraudulent info - rules don't stop people like that in the same way sternly telling a mugger that it's illegal won't stop them from taking your wallet. Checks & balances sure but beyond a certain level of illegality more rules achieve nothing.


Analysis by Global Witness shows 87,000 properties – 40% of them in London – are anonymously owned by firms registered in tax havens

https://www.google.com/amp/s/amp.theguardian.com/uk-news/201...


Would be curious what you (and the guardian) reckon "anonymous" means in this context?

Shareholder data for private companies aren't generally publicly searchable regardless of country...(hence the "private" part)


From following the Vancouver/BC/Canada real estate market, this is very common and normal. (related : Vancouver BC reaching third most expensive city in the world status a couple of years back, for reasons that have little or nothing to do with local populations)

The closest I can get to sources though: https://www.cbc.ca/news/canada/british-columbia/laundered-mo... https://www.cbc.ca/radio/podcasts/current-affairs-informatio...


>related : Vancouver BC reaching third most expensive city in the world status a couple of years back, for reasons that have little or nothing to do with local populations

What is it due to? I imagine ease of access to Chinese people who want a place to park their savings, plus nice weather, are the biggest factors. After all, all those wealthy Chinese people could just go to another city, like Edmonton, but they don't: what kind of insane person would want to live in a place where it's -40 in the winter if they didn't grow up there?


- Accessibility to flights

- A large chinese community already being there, seeded by the HK hand over to china. The HK wave did not cause a real estate crisis.

- Being known as a "good investment" in China.

- RE firms that market in china for vancouver.

- Most importantly of all, bad enforcement of money laundering and foreign income laws compared to the USA.

If money laundering and tax laws were enforced as badly as Canada in the USA, I bet many of these chinese would be in the USA. The pacific north west is not considered a good place weather wise in the USA.


>The pacific north west is not considered a good place weather wise in the USA.

Where did you get that crazy idea? The PNW is known for being mild, though rainy and not terribly warm. People who like a lot of sun wouldn't like it. But compared to most parts of the country, it's known for "good" weather: in the northeast, it's snowy and brutally cold during the winter. In the southeast, it's brutally hot and humid during the summer, and there's hurricanes. In the (desert) southwest, it's horrifically hot during the summer. In the middle/plains states, it's brutally cold in the winter and there's regular tornadoes. In the Dakotas/Minnesota area, it's horrifically cold in the winter. The PNW doesn't have any of that stuff. Compared to southern California, the weather may not seem as nice to many people, but most of the rest of America does not have the consistently mild and warm weather year-round that SoCal has. But PNW does have consistently mild weather year-round for the most part, albeit without so much sun, and a lot of rain.


A lot of random people I run into in the USA make icky faces when I tell them about the PNW and it's weather. I've also lived there for many years, there are many climates in the USA I would prefer over the PNW, since AC is a thing.

Also bay area weather is pretty perfect too.


Such a mess that lawyers got exempted from a bunch of money transfer reporting regulations.

I get the need for lawyer-client confidentiality if you’re on trial for murder.

You don’t need it if you’re buying property.


Climate change has made it much nicer during the real estate boom! 2013-2016 had great summers and no smoke.


Really healthy support of money laundering by other countries (eg USA, Russia). People blame China "because visible". Although chasing the money there it more seems like China too is making for a nice place for ultrarich (1%) and others (eg drug dealers) trying to dodge taxes or other laws in various countries.

There's no data tracked though, and outside of the RCMP investigation there's basically no public information beyond speculation of possible causes.

Other than it's not population pressure. There's very large ties between Vancouver, India and China visibly - but nothing to the degree costs hit. I found living there that the influences of India and China helped moderate things and help the city be more liveable.


Very broadly speaking this is what KYC (know your customer) regulation is for which not only deals with the party in business with the financial institutions but also more importantly with the beneficiary of whatever entity this is. So in your example the bank would be under the obligation to ask prior to establishing any business relationship with the shell corporation where does the money come from and where do any gains etc. go to.

However if the controller does not do his or her job properly or gets coerced by either the client or the asset manager to enter false or incomplete information this regulation is obviously not very effective and requires regular auditing by the authority (in the case of Switzerland FINMA which is the equivalent of the FTC)

There are much better and most importantly legal ways to “optimize taxes” than a simple shell corp. Some of these “corporate constructs” or however you want to call it use loopholes “double Irish with a dutch sandwich” is one of the most notorious ones.


Wouldn't a logical next step to extend this to all countries that USA + EU trades with? Banking moves slowly, so it will take many years, but I don't think Panama will be able to hide stuff in 50 years from now.

If they can strongarm the Swiss, why shouldn't they be able to do it to a lot of other countries who want to trade with USA+EU ?


In my personal opinion individuals entirely hiding their assets from their native governments is a thing of the past. Why hide your assets and risk going to jail when you could just pay a consulting firm a fixed amount of money to optimize your tax rate and deductibles to the point where you essentially pay nothing at all.


You would have to deal with UK CFC reporting.


This is not something that Switzerland was happy to do; it took a lot of pressure to get them to stop being an asset haven for international tax avoiders.


Minor technicality, but tax avoidance is legal. Saving in a tax-advantaged account is tax avoidance. The problem with what Switzerland was doing is that it was aiding and abetting tax evasion.

Most of the time people get this wrong the other way. I've never seen the evasion->avoidance transposition. So, I thought I might share. No harm meant. :)


To be precise: pressure from the US. Now the US is Switzerland.


Many people are missing this point. US banks, until this point, do not exchange information on their foreign customers. FATCA is more like: Hey Hong Kong, Swiss, London, nice business you have over there, maybe I can get in the action too. All of the action actually.


And as a result of that the US is now the worlds largest offshore banking center for the rest of the world. It's a pretty safe place to hold your money, after all.



Don't worry, Switzerland is still attractive for many reasons as a stable, competitive, well connected financial center.

I think a lot of people don't realize that bank account privacy is just 1 of 20 distinctive qualities of Swiss institutions and regulatory structure.

Switzerland is attractive because its not just shell companies and PO boxes, compared to other nations that try to offer similar nominal regulations. Instead it has a vibrant regulatory system with competition amongst each state and no expensive federal government. As an example Google pays the same as it does in Silicon Valley, with employees being only subject state level tax. The state of Zug is a fintech hub with an income tax rate of 7%. Territorial only. The Swiss franc is currently pegged 1:1 with USD, having ditched Euro peg almost 5 years ago.

The regulators and public sector representatives are very accessible because everything happens at the sparsely populated state level, and they all operate under the swiss brand which includes access to the global financial system.

Switzerland is better thought of as a loose collection of sovereign states with a small national government. The concept may seem familiar but recognize how small all of Switzerland is and that has factored into why the national government never grew arbitrarily large to maintain cohesion and assume its own intrusive identity, and why direct representation has been possible there for almost 200 years (they did represenative democracy before that, like the US, but figured out how to remove it since the flaws were obvious and they're smaller)

Outside of finance and regulatory structure, Americans may also find the vibrant gun culture and visible military to be refreshing and familiar. A stark contrast to the ideals and vocal opinions that neighboring Europeans would have about guns as soon as they find out you're American, possibly unaware of what Switzerland offers and has offered for a very long time.


> The Swiss franc is currently pegged 1:1 with USD, having ditched Euro peg almost 5 years ago.

It's not.


The Swiss central bank actively tries to maintain parity

Use whatever word you want to quickly convey that thought to a broad population

“Peg” also does that.


Over the last four years the USD has moved in the range 0.92-1.03 CHF (a +/- 5.6% interval around the midpoint). The average rate is 0.985, the standard deviation 0.019 (2.0%).

Over the last four years the EUR has moved in the range 1.06-1.20 CHF (a +/- 6.0% interval around the midpoint). The average rate is 1.117, the standard deviation 0.034 (3.1%).

Even though the exchange with the USD is slightly more stable in this case (it depends on the period and metric chosen) saying that it's pegged is an exaggeration.

By the way, the CHF was not pegged to the EUR either. There was a minimum rate set by the SNB at 1.20 but it floated as high as 1.26 in 2013.


> ... but it floated as high as 1.26 in 2013.

Just before they abandoned the peg as too hard to maintian.


Maintaining the 1.20 floor (not peg) is not hard when the CHF is weakening against the EUR, the SNB doesn’t need to do anything at all when the exchange rate is moving in the direction they want.

They abandoned the floor more that a year and a half later, in January 2015, when the exchange rate was back at 1.20 despite their efforts to keep CHF appreciation under control.


I mean I've seen state sponsored pegs that had a greater standard deviation than this non-peg.

Thanks for the quantitative response, I just don't find it a productive conversation to what the point was.


Swiss banks doesn't actually disclose to swiss authorities, even though the have a wealth tax based partially on the money in your bank account.


> Swiss banks doesn't actually disclose to swiss authorities, even though the have a wealth tax based partially on the money in your bank account.

(i'm swiss)

I believe there is no way in hell they could have passed this legislation if it included giving data of swiss citizens to the swiss government.

People here cherish their banking secrecy and it's still somewhat part of the national identity.

From a swiss point of view it was/is pretty much: The US is pressuring us too much, we'll have to give up banking secrecy, but only for foreigners.

If they didn't do that, i'm fairly certain it would have been shot down by the people with a referendum.


> From a swiss point of view it was/is pretty much: The US is pressuring us too much, we'll have to give up banking secrecy, but only for foreigners.

Exactly, this is also what neighboring Austria did a few years ago.

It is nice that Switzerland takes the attention for "banking secrecy" because other countries that have it in law get to fly under the radar.

As always, people that have better reading comprehension skills get their advantage.


After the 2009 financial crisis and the regulatory requirements which followed the major international Swiss banks were forced to split their retail and investment business into separate entities at about the same time they also started restructuring some other things I am pretty sure they saw this coming after FATCA / MIFID because they have all since split their Swiss business from their international business at least legally (separate legal entities under one brand and holding corp etc.)


I loved in Switzerland recently, and I never really understood how the wealth tax works when the banks don't talk to the tax authorities. Is it entirely optional?


You fill out a tax declaration every year. If you don't disclose some values and this is discovered later on, you will be punishable with a fine (between 30% and 300% of the tax on the non-disclosed values). The fine can be avoided in some cases by self-indictment, but of course you'll still have to pay the avoided taxes plus interest.

If you even fake documents to avoid taxes, then you can end up in jail.

This system of "voluntary" tax declarations is like a contract between the government and the citizens: Government doesn't stick their nose into bank accounts of citizens, while citizens pay taxes on their assets. I'm not sure if it's a good system, but it has mostly worked out so far.


Under reporting is possible to some extent everywhere, that doesn’t mean that paying taxes is “optional”.

Hidden money cannot be spent and as soon as it surfaces you would have quite some explaining to do.


Over reporting is actually beneficial, because at the end of the year you can file a correction and the government will refund you the difference, plus interest. The interest rate, while not amazing, is better than any bank would give.


I have to say that I find the attitude I quoted below from the link, ever more prevalent in today's political and social climate, to be extremely dangerous in how one-sided it is.For one thing, competition is a cornerstone of better development. Yes, it sometimes needs to be moderated but as a basic rule of anything economic, it works at delivering more and better options and keeping exploitative tendencies in check. This applies to the regulatory frameworks of countries just as much as to any other economic actor and the just as many of us would probably agree that it's a bad idea for every company in X industry to collude on fixing prices, the notion of stamping out competitive tax regimes among nation states should be looked at with the same suspicion and for the same reasons of curtailing abuse against those who have to pay for everything.

Secondly, at what point does it allow for the question of just how much government should be allowed to spend? The entire onus should not simply be placed on crushing tax avoidance, and a serious debate about the size, scope and sheer spending done by governments today needs to balance things out. This isn't an argument against social programs or helping the poor it's just a recognition of the basic fact that a tremendous amount of money extracted by states gets wasted on all sorts of immense bloat. We complain about bureaucratic mismanagement by various countries all the time but for some reason should applaud their obsessive efforts to crush any exit valves on abusive tax practices by them, and not just tax avoiders or evaders?

With the support of the G20 and the EU, the Organisation for Economic Cooperation and Development (OECD) therefore drew up international standards in 2014 to enable countries to exchange bank information automatically. More than a hundred countries have so far decided to adhere to these standards, almost half of which have already started to exchange information in 2017. Participating countries must undertake to treat the data they receive confidentially and only for tax purposes.

These rules also aim to create a level playing field for all financial centres by putting an end to tax havens. Countries - or territories - that do not meet the criteria set out in international standards or that are not cooperative are included in grey or black lists of the OECD and the EU. “Defensive measures", in other words sanctions, are envisaged against them.


A related read: Swiss bank employees who are domiciled outside Switzerland are exempt from Swiss banking secrecy laws.

https://www.economist.com/finance-and-economics/2018/10/18/a...

Also at https://archive.is/lbO8j




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