Information to International Client of FATCA AGREEMENT

RECOMMENDATION TO US INTERNATIONAL CLIENT

The FATCA agreement and the act itself will enter into force by 1 July 2014.

Within the scope of the implementation of the FATCA agreement, all banks are required to disclose information on US accounts to the US Internal Revenue Service (IRS) This Firm would like to take this opportunity to advise its United States (US) Citizens and residents about the Foreign Account Tax Compliance Act (FATCA) and its significance to the parties concerned and their accounts held with Swiss and European Bank’s. The Foreign Account Tax Compliance Act (FATCA) is an Act legislated under the laws of the United States of America (US) that requires US Persons to report their financial accounts held outside the United States and for foreign financial institutions to report to the International Revenue Service (lRS) about their American client. Failure or non-compliance with the Act results in a 30% withholding of certain payments to accounts held by non-cooperating citizens.

FACTA agreement applies to all domestic and international offshore financial institutions operating in all offshore countries. US bank clients receive a letter from their bank, in which the bank requests their consent to its reporting of their account information to the IRS. Enclosed with the letter is an information letter from the FTA describing the steps involved in a possible administrative assistance procedure under the FATCA agreement. The United States can request administrative assistance only after it has received the aggregate reports from the bank and once the Protocol of Amendment to the double taxation agreement of 23 September 2009 has entered into force. This firm is available to give all assistance that you need to carry out your tax position.

With Regards

Avv. Mario Paolo D’Arezzo LL.M, PdD