27.03.2015 1'

Non-Consenting U.S. Accounts

On March 24, 2015 the IRS announced that, with respect to calendar year 2014, Model 2 FFIs that have to report Non-Consenting U.S. Accounts will not be treated as being in significant non-compliance under their applicable Model 2 IGAs as long as they are making good faith efforts to comply with their reporting obligations and reporting is completed within 90 days after the applicable filing deadline, including any extensions already granted.

All news

On March 24, 2015 the IRS announced that, with respect to calendar year 2014, Model 2 FFIs that have to report Non-Consenting U.S. Accounts will not be treated as being in significant non-compliance under their applicable Model 2 IGAs as long as they are making good faith efforts to comply with their reporting obligations and reporting is completed within 90 days after the applicable filing deadline, including any extensions already granted.

Based on this IRS publication, and the fact that the Swiss State Secretariat for International Financial Matters (SIF) was already able to receive an extension of the reporting deadline for non-consenting U.S. Accounts until March 31, 2015, the Swiss Bankers' Association announced in Circular 7848 that the deadline for Swiss Financial Institutions to report on Non-consenting U.S. Accounts has been generally extended to June 29, 2015. Due to the "good faith" language, however, we recommend that Financial Institutions that are ready to report by the March 31st deadline do so, and that all others report as soon as technically feasible.

News

09.01.2026 19'

2026 Reporting Reminder

We would like to inform all Swiss financial institutions on their reporting requirements under CRS, FATCA and QI. The QI Reporting Requirements outlined in this newsletter will also be applicable to non-Swiss QIs. For the non-Swiss CRS and FATCA reporting requirements, the respective local implementation guidance must be consulted.

23.12.2025 6'

2025 Year Wrap-up and Outlook

While CRS 2.0 will enter into force as scheduled on 1 January 2026, the entry into force of the Swiss CARF provisions has been postponed until at least 2027. As a result, both CARF reporting and due diligence obligations are deferred, providing affected financial institutions with additional time for preparation. At the same time, further regulatory developments are coming into focus, including the revised FATCA agreement (expected to enter into force no earlier than 1 January 2027), new electronic filing requirements in the QI environment, and the postponed introduction of the German MiKaDiv reporting obligations by the end of 2026.

23.09.2025 5'

Approval of PQS as authorized 1042 e-Filer and Upcoming e-Filing Obligations

Due to the upcoming changes in the e-filing obligations of the Form 1042, PQS applied for the required status as Electronic Return Originator and Transmitter with the IRS to be able to file Form 1042 and its attachments electronically via the Modernized e-File Platform (MeF) and has recently attained this status. With this newsletter, we would like to inform you about the significant changes in the e-filing obligations of the Forms 1042 and 1042-S, which will have an impact on all filers such as Qualified Intermediaries (“QIs”), Qualified Derivatives Dealer (“QDDs”) and Withholding Foreign Partnerships (“WFPs”) as well as our new e-filing service for Form 1042 and its attachments.