Avamprogetto (Accordo en)

transmitted to the FTA, and (4) the FTA may exchange this information with the IRS in accordance with Article 5 of this Agreement;

(ii) report annually to the IRS, in the time and manner required by an FFI Agreement and relevant U.S. Treasury Regulations, the aggregate

information required with respect to Non-Consenting U.S. Accounts; and

(iii) notwithstanding subparagraph (ii), report to the IRS the aggregate number and aggregate value of all Non-Consenting U.S. Accounts no later than January 31 of the year following the year to which the information relates;

and

c) with respect to New Accounts identified as U.S. Accounts, obtain from each

Account Holder a consent to report consistent with the requirements of an FFI Agreement as a condition of account opening.

2. For purposes of reporting with respect to calendar years 2015 and 2016, Switzerland shall also direct all Reporting Swiss Financial Institutions to:

a) with respect to accounts of, or obligations to, Nonparticipating Financial

Institutions that exist as of December 31, 2013, and in connection with which the Reporting Swiss Financial Institution expects to pay a Foreign Reportable Amount,

(i) request from each such Nonparticipating Financial Institution a consent,

covering irrevocably the current calendar year and automatically renewed for each successive calendar year unless revoked before the end of January of such year, to report and simultaneously inform the Nonparticipating Financial Institution through a letter of the FTA that, if such consent is not given, (1) aggregate information about Foreign Reportable Amounts paid to the Nonparticipating Financial Institution shall be reported to the IRS, (2) such information may give rise to a group request by the IRS for specific information about the account or obligation, (3) in such case, the

information about the account or obligation shall be transmitted to the FTA, and (4) the FTA may exchange this information with the IRS in accordance with Article 5 of this Agreement;

(ii) report to the IRS the number of non-consenting Nonparticipating Financial Institutions to which Foreign Reportable Amounts were paid during the year and the aggregate value of all such payments no later than January 31 of the year following the year to which the information relates; and

b) with respect to new accounts opened by, or obligations entered into with, a

Nonparticipating Financial Institution on or after January 1, 2014, and in

connection with which the Reporting Swiss Financial Institution expects to pay a Foreign Reportable Amount, obtain from each such Nonparticipating Financial Institution a consent to report consistent with the requirements of an FFI

Agreement as a condition of opening the account or entering into the obligation.