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All I can say is that my wife converted her pension from AT&T to Roth IRA's in addition to our contributing each year once she lost her job in 1998. We also contributed each year to Coverdale Educational IRA's for our two children. Before agreeing to come to Switzerland from the US we asked Deloitte about these accounts - they told us they were not subject to wealth taxes. Well for 2013, everyone we had talked with from Deloitte left or were fired - and we were told we had to declare these "private pension accounts" as wealth. We are now being creamed by wealth taxes in Baselland which is slowly eating away at my wife's retirement (and me also without a pension) that is driving us to leave Switzerland within 2 months.
Be careful - we have never had so much grief over taxes and returns in our 28 years of working. Swiss taxes are a nightmare, and we are finding that Deloitte and other advisors are not eager to help argue for the rights of Americans working here or explaining the intentions or restrictions on private pension accounts.
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The 'wealth tax' will get you, often. BUT: Swiss tax law (and Civil Code) was not drafted with trusts in mind. (Once the banks decided they wanted the benefits of The Hague Convention on Trusts Switzerland did ratify it.) And cantonal tax authorities do not necessarily understand tax treaties.
You won't get proper advice on a forum, of course. And paying big bucks doesn't even mean you'll get better advice.
The spouse of one of my best friends works for Deloitte. First in the USA, now in the UK, and about to return to the USA. What does she say? "I'm an administrator. I would never work on the accounting or tax side. Never."
And let me add a Postscript. One time I had to resolve a problem for my (then) employer on Puerto-Rican mirror tax issues in relation to US federal tax. At the same time I was dealing with my mother's estate. I asked the IRS estate tax audit lawyer to refer me to somebody who knew something about this esoteric problem. He gave me a telephone number in Washington and added this: in any tax agency there may be one and only one person who knows what s/he is talking about when it comes to some difficult (especially international) matter. If you look online at some of the IRS Revenue Rulings you will see what I mean. There is probably some one person in Berne who knows how to deal with this American problem and s/he probably sees or speaks to or writes to his/her American colleague from time to time. Find that person. Don't waste your money and your time with the Big 4.
Funny thing this: when I got to speaking to the PR guy in Washington, he told me his sister had married a Brit and was living in rural England. And wanted to know what I knew about life in England. Meanwhile the IRS audit lawyer was curious to know what I knew about Algeria. (Never mind, I know something).
But that was long ago, and this is now. Still, I doubt much has changed.
Except that I met once, with tax questions, with a cantonal tax person, a specialist in international tax. It turned out he was new on the job and I knew more than he did. Still, he tried to be helpful. Really, not all tax enforcers are cerbères rébarbatifs
. I found, in my long career that intermediaries, so-called experts, often knew less than I knew, or could find out. Of course the US Tax Code & Regs, and Simon's Taxes in the UK, have twice as many pages as in my day.
The Swiss cantonal tax declarations are daunting. I remember once refusing to fill out the forms from one canton and instead giving them the forms I'd filled out from another, and just signing the declaration. I did that for a few years: they went along with it. I have to say this: the Swiss are more reasonable than the IRS. Which reminds me of something an Inland Revenue guy (as they then were) once told me: We watch TV too. Unlike the IRS we are not gangbusters.
That too was then, and this is now. What do I know.