Deadline Extension for US Accounts Without Declaration of Consent

On January 20, 2015, the SBA published the circular no. 7878 (password required) on aggregated reporting of the non-consenting US accounts for the calendar year 2015. 

The SBA informs that the Swiss State Secretariat for International Financial Matters (SIF) negotiated with the US Department of the Treasury for a one-time extension of time to file the reporting of non-consenting accounts. The US Department of the Treasury confirmed that the US does not consider the aggregate reporting of non-consenting US accounts for calendar year 2015 by March 31, 2016 (the previous deadline – Jan 31, 2016) to be reason for significant non-compliance with the FATCA IGA. The SBA remarks, however, that the extension of time to file will not be applicable for the reporting of non-consenting accounts held by non-participating foreign financial institutions (NPFFIs). The official notification from SIF can be found at the SIF homepage. 

In order to benefit from the extension of time to file and avoid punishment, reporting Swiss financial institutions are required to notify the Federal Tax Administration (department of crime and investigation). Reporting Swiss financial institutions are advised to inform the FTA immediately by means of a registered letter. Further information can be obtained with the FTA.