The Swiss-U.S. ‘Turnover’ Ground Rules: A Technical Update

Article by Walter H. Boss and William M. Sharp Sr.

Walter H. Boss is with Poledna Boss Kurer AG in Zurich and William M. Sharp Sr. is with Sharp Kemm P.A., Tampa, Fla., and Zurich.

The authors gratefully acknowledge the review comments of their colleagues, Larry R. Kemm, Sharp Kemm, P.A., Tampa and Zurich, and Milan K. Patel, Sharp Kemm, P.A., Zurich.

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. A great deal of confusion exists on this topic, and our objective is to provide technical clarification to this highly complex developing story.