International Tax
US Tax Attorney for Americans in Switzerland and Swiss Account Holders
Switzerland is synonymous with banking privacy — but Swiss bank secrecy has been substantially dismantled for US taxpayers under FATCA and UBS/Credit Suisse agreements. The US-Switzerland tax treaty and the Swiss banking landscape create a unique compliance environment for US persons.
Key US Tax Issues for Switzerland
Swiss Bank Accounts
Swiss bank accounts are among the most scrutinized foreign accounts by the IRS. Under FATCA, Swiss banks report US account holders to the IRS. US persons with Swiss accounts must file FBARs and, if over the FATCA threshold, Form 8938.
Swiss Pension Pillar 2 and 3a
Swiss occupational pension (pillar 2 / BVG) and voluntary pension savings (pillar 3a) require careful US tax treatment. Treaty provisions and IRS rulings provide limited guidance.
Swiss Investment Products
Swiss private banks often offer structured products, foreign funds, and investment vehicles that may qualify as PFICs. Annual Form 8621 may be required.
Undisclosed Swiss Accounts (Historical)
Taxpayers who previously had undisclosed Swiss accounts and have not yet come into compliance should consult an attorney immediately. The IRS and DOJ continue enforcement actions related to Swiss account non-disclosure.
Common Questions
Does Switzerland still have bank secrecy for Americans?
No. Switzerland signed FATCA agreements and the US received account information from UBS, Credit Suisse, and most major Swiss banks. Swiss bank accounts are not hidden from the IRS.
What should I do if I have an undisclosed Swiss account?
Consult an attorney before doing anything else. Depending on whether your non-compliance was willful, you may qualify for the Streamlined program (reduced penalty) or need to use the Voluntary Disclosure Program.
Free · Confidential · Remote-Friendly
Speak with an attorney about your Switzerland situation
Consultations are conducted by phone or video. No need to travel to Beverly Hills.