This article provides a technical update in light of many media reports that the ongoing negotiations between the U.S. and Swiss governments will purportedly result in a global tax settlement agreement with an immediate turnover of Swiss banking data otherwise protected by Swiss bank secrecy law.

What are the differences in tax treatment between an acquisition of stock in a company and the acquisition of business assets and liabilities?

Switzerland's direct tax system functions at three jurisdictional levels. In addition to Federal income taxes, the 26 Cantons (States) and the more than 2,500 communes (municipalities) levy their own income taxes.

Where an individual has a personal affiliation with Switzerland as a result of the establishment of tax domicile or tax residence, the individual is subject to unlimited Swiss tax liability.