AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND THE SWISS

1 THE UNITED STATES OF AMERICA and THE SWISS CONFEDERATION hereinafter referred to as "the Contracting Parties", WHEREAS, the Contracting Parties seek to reaffirm and ...
irs.gov/pub/irs-drop/us-swiss_government_agreement.pdf

 

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THE UNITED STATES OF AMERICA WHEREAS, Article 1 Treaty Request 1. The Swiss Confederation For these accounts UBS will provide a notice to account holders under the Treaty Request. They will (i) be subject to a final decision of the SFTA under t he treaty process, or (ii) be transmitted to the IRS as a result of the accountholder having provided UBS or the SFTA with a waiver to submit such account information directly, or (iii) fall out of t holders have provided consent to the SFTA to request copies of Article 2 Revised Tax Treaty Article 26 (and certain other provisions) of th e Tax Treaty, initialed on June 18, 2009, as Article 3 Withdrawal of the John Doe Summons 1. Immediately after the si to the enforcement action concerning the 2. Subject to the terms of Article 5 of this ates shall not seek he JDS while this Agreement remains in force. 3. Subject to UBS AG’s compliance with Arti 4. The United States shall withdraw t with regular updates about the number of 5. Subject to UBS AG’s compliance with Arti terms of Article 5 of this Agreement, the For purposes of this paragraph, the term “any source” means account information disclosed (i) under S’s voluntary disclosure practice, ( iii) as a result of waivers for UBS or the SFTA to submit account information to the IRS, or (iv) under the Deferred Prosecution Agreement between UBS AG and the United Stat es of America, dated February 18, 2009. Furthermore, the IRS shall to the extent feasib le, include account information disclosed through FBAR filings made after the signing of this Agr Article 4 Compliance by UBS 1. In the separate agreement tion covered by the Treaty Request according to the following time frames: within 60 days after UBS AG receives notice from the SFTA that the Treaty within 180 days after UBS AG receives the remaining cases referred to in t he Annex under paragraphs 2.A.b and 2.B.b, within 270 days after UBS AG receives 2. In the separate agreement 3. The Swiss Federal Office of Justice (SFO The Annex will be disclosed to UBS AG under the same confidentiality requirements. Article 10 Duration and Termination This Agreement shall remain in force until