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Anais Donnee
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Recent statements made by experts from the Federal Tax Administration ("FTA") towards Swiss fund managers and banks seem to have created confusion among industry participants, advisors and the FTA. Did the FTA in fact break a well-established industry practice or just reemphasize what is, in its view, the application of... Continue reading
Posted Feb 18, 2016 at Banking blog
As of 1 January 2016, the United States will impose a worldwide withholding tax on U.S. equity derivatives based on the New 871(m) Regulations. The novelty of these New Regulations is their extra-territoriality component as a withholding tax will be imposed even where neither the issuer nor the consumer has a link with the U.S. and which is solely based on the type of the underlying asset referenced in the derivative contract. For example, a Swiss financial institution selling a U.S. equity derivative to a non-U.S. individual may, under these new rules, be required to withhold and report to the Internal Revenue Service (IRS) on this specific product solely because of the asset it is referencing. This exposes financial institutions to a major challenge due to the implications on the operations, IT and the business. Continue reading
Posted Nov 11, 2015 at Banking blog
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Mar 19, 2015