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Switzerland vs United States

Crypto regulation comparison

← Back to map | Switzerland | United States
Switzerland

Switzerland

United States

United States

Legal
Legal

Switzerland is one of the world's most crypto-friendly jurisdictions. The Canton of Zug is known as 'Crypto Valley' and hosts the Ethereum Foundation and hundreds of blockchain companies. FINMA provides clear regulatory guidance, and the DLT Act (2021) created a legal framework for tokenized securities and crypto exchanges. Individual investors pay no capital gains tax on crypto, though it is included in the cantonal wealth tax base. Professional traders may be subject to income tax.

The United States has the world's most complex crypto regulatory landscape, with overlapping federal and state jurisdictions. The SEC regulates crypto securities and has pursued enforcement actions against exchanges and token issuers. The CFTC oversees crypto derivatives and considers Bitcoin a commodity. FinCEN applies BSA requirements to crypto exchanges as money service businesses. The IRS taxes crypto as property: short-term gains at income tax rates (10-37%), long-term gains at 0-20%. New 1099-DA broker reporting rules take effect from 2025. Multiple states have their own requirements, with New York's BitLicense being the most stringent.

Tax Type Wealth
Tax Type Capital gains
Tax Rate 0% capital gains (individuals); wealth tax varies by canton
Tax Rate 0-37%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FINMA (Swiss Financial Market Supervisory Authority)
Regulator SEC, CFTC, FinCEN, OCC, IRS, State regulators
Stablecoin Rules Regulated under FINMA framework; fiat-pegged stablecoin issuers must hold a banking or fintech licence (reserves treated as public deposits), or a payment system licence under FMIA if structured as financial market infrastructure
Stablecoin Rules Stablecoin legislation actively being developed in Congress; existing oversight by SEC, CFTC, state regulators
Key Points
  • No capital gains tax on crypto for individual investors (private wealth management)
  • Crypto included in cantonal wealth tax base (rates vary by canton, typically 0.1-1%)
  • Professional/frequent traders may be classified as self-employed and taxed on income
  • FINMA regulates crypto under existing financial market laws and the 2021 DLT Act
  • DLT Act (2021) introduced DLT trading facility license and legal framework for tokenized assets
Key Points
  • SEC regulates crypto as securities under Howey test; major enforcement actions (Ripple, Coinbase, Binance)
  • CFTC classifies Bitcoin and Ether as commodities; oversees derivatives markets
  • IRS treats crypto as property: short-term gains taxed at 10-37%, long-term (1yr+) at 0-20%
  • FinCEN requires exchanges to register as MSBs and comply with BSA/AML requirements
  • 1099-DA broker reporting for centralized exchanges effective from tax year 2025
Sources
Sources