[tsmith130]

And should this provision be deemed illegal by a given foreign nation's domestic laws (think Switzerland), well the foreign financial institution is required to close the account.

How can they 'require' a foreign financial institution to close an account? (I know...I know...humor me)

[Candor7]

How can they 'require' a foreign financial institution to close an account? (I know...I know...humor me) >>>>>>>>>>>>>>>>>>>>

By tax treaty. We have reciprocal enforcement treaties with most nations except a very few.

[HiTech RedNeck]

Going to the new tax code itself, it sounds like this applies to accounts in the USA (as with a Swiss bank that does business in the USA). There is no means other than treaty or war to do it otherwise, any more than Canada can force the closure of my personal bank account with a United States bank.