To Disclose or not to Disclose? A Discourse on Switzerland’s New Federal Tax Act

A new Federal Act on the Simplification of Additional Tax Assessments in Succession Matters and the Introduction of a Tax Amnesty for Voluntary Declarations (hereinafter "the New Act") will come into force in Switzerland on January 1, 2010. The purpose of the New Act, which will modify the Federal Act on the Federal Direct Tax (LIFD) and the Federal Act on Harmonisation of Direct Taxes (LHID), is to encourage taxpayers (individuals and businesses) to report in their tax returns those elements of wealth, income and/or capital and profits, prior thereto undisclosed.