Switzerland consistently ranks among the top destinations for American expatriates seeking quality of life, career advancement, and political stability. Between 2020 and 2025, the American expat community in Switzerland grew by 18%, driven by remote work flexibility, attractive financial sector opportunities, and family reunification. However, moving from the US to Switzerland presents unique challenges that differ significantly from relocating within North America or to other European countries.
Unlike European Union citizens who benefit from freedom of movement, Americans face strict immigration quotas, complex dual tax obligations, and substantial differences in healthcare systems. Success requires understanding the US-Swiss tax treaty, navigating Swiss cantonal variations, and preparing for cultural adjustments that go beyond language barriers. This comprehensive guide addresses the practical, financial, and regulatory considerations that matter most to Americans planning their Swiss relocation.
Understanding the US-Swiss Tax Treaty
American citizens face a fundamental reality that distinguishes them from virtually all other nationalities: the United States taxes based on citizenship, not residency. Even after establishing Swiss tax residency, you remain obligated to file US federal tax returns annually. The US-Swiss tax treaty, originally signed in 1996 and updated through subsequent protocols, exists to prevent double taxation whilst ensuring both countries receive their due revenue.
The treaty's most critical provision for ordinary wage earners is the foreign tax credit mechanism. Swiss federal and cantonal income taxes are generally higher than US federal rates, meaning most Americans can claim sufficient foreign tax credits to eliminate US federal tax liability. However, this does not mean zero US tax obligations—it means your Swiss taxes typically satisfy your US requirements. You must still file Form 1040, along with Form 1116 (Foreign Tax Credit) and Form 2555 if claiming the Foreign Earned Income Exclusion (FEIE).
FATCA and FBAR reporting represent significant compliance burdens unique to Americans. The Foreign Account Tax Compliance Act requires Swiss banks to report accounts held by US persons directly to the IRS. Simultaneously, you must file FinCEN Form 114 (FBAR) if your aggregate foreign financial accounts exceed $10,000 at any point during the calendar year. This includes Swiss bank accounts, pension funds, and investment accounts. Penalties for non-compliance are severe—up to $100,000 per violation for non-wilful failures, and 50% of account balances for wilful violations.
State tax obligations add another layer of complexity. Whilst moving abroad terminates tax residency in most states, seven states with no income tax (Alaska, Florida, Nevada, South Dakota, Tennessee, Texas, Wyoming) and two others (New Hampshire, Washington) make this straightforward. However, states like California, Virginia, and South Carolina maintain more aggressive residency rules. California, particularly problematic for expats, may continue asserting tax jurisdiction unless you demonstrate definitive intent to abandon residency—selling property, surrendering driving licences, and registering to vote elsewhere all help establish this intent.
Tax scenario example: An American software engineer moves to Zurich in 2026, earning CHF 150,000 annually. Swiss federal tax on this income approximates CHF 12,000, whilst Zurich cantonal and municipal taxes add roughly CHF 15,000, totalling CHF 27,000 (approximately $31,000). US federal tax on equivalent income ($165,000 at 1.10 exchange rate) would be approximately $28,000 for a single filer. After claiming foreign tax credits for Swiss taxes paid, the American's US federal liability reduces to zero. However, they must still file US returns, FBAR, and potentially Form 8938 (Statement of Specified Foreign Financial Assets) if meeting thresholds.
The treaty also addresses specific income types. Swiss withholding tax on dividends from Swiss companies is limited to 15% (reduced from the standard 35%), whilst interest and royalties face different treatments. Pension contributions present particular complexity—US 401k contributions receive no Swiss tax relief, whilst Swiss pension pillar contributions (2nd and 3rd pillars) may not be deductible on US returns without careful structuring.
Visa Options for Americans
Americans do not qualify for EU freedom of movement, placing them in the same category as other third-country nationals subject to strict Swiss immigration quotas. The Federal Council sets annual limits on work permits, with approximately 8,500 B permits (residence permits) and 4,500 L permits (short-term permits) available for non-EU/EFTA nationals across all of Switzerland. Cantonal authorities allocate these permits, creating regional variation in difficulty.
L permits suit Americans on intra-company transfers or fixed-term contracts under 12 months (extendable to 24 months maximum). Major multinational corporations—particularly in pharmaceuticals (Roche, Novartis), banking (UBS, Credit Suisse), or technology (Google Zurich, Microsoft)—utilise these permits for transferring American employees. The company must demonstrate that the position requires specific expertise unavailable in the Swiss or EU labour market. L permits do not lead directly to permanent residence, making them suitable for temporary assignments rather than permanent relocation.
B permits serve as the primary route for Americans planning long-term relocation. Valid initially for one year and renewable annually, B permits eventually convert to permanent residence (C permit) after ten years of continuous residence (five years for US citizens under certain conditions due to bilateral agreements). Obtaining a B permit requires a Swiss employer to demonstrate labour market priority—proving they cannot fill the position with a Swiss or EU candidate. This requirement proves far more stringent than Americans typically experience with US employment sponsorship.
Quota reality check: Switzerland's non-EU quota exhausts early in the calendar year, particularly in popular cantons like Zurich, Geneva, and Zug. Applications submitted in autumn face significantly reduced chances compared to January submissions. Employers with established track records of hiring foreign specialists receive priority consideration, favouring large corporations over startups or small businesses.
Family reunification permits allow spouses and children under 18 to join B permit holders, though spouses initially require separate work authorisation. Americans married to Swiss citizens follow an easier path, qualifying for permits outside the quota system after demonstrating genuine relationship and adequate accommodation.
Self-employment or entrepreneurship presents additional challenges. Americans seeking to establish Swiss businesses face higher capital requirements and must demonstrate substantial economic benefit to Switzerland. Freelance permits exist but remain difficult to obtain without existing Swiss client base and residence.
Health Insurance Transition
The transition from American employer-sponsored health insurance or individual marketplace coverage to Switzerland's mandatory system represents one of the most significant adjustments for American expats. Understanding how to manage the gap between leaving US coverage and establishing Swiss residence is critical to avoiding coverage lapses and financial penalties.
Leaving US employer plans: COBRA continuation coverage allows you to maintain employer-sponsored health insurance for up to 18 months after employment termination, though you pay the full premium plus 2% administrative fee. For Americans leaving US employment to move to Switzerland, COBRA provides temporary coverage during the transition period but becomes prohibitively expensive—often $600-800 monthly for individual coverage, $1,500-2,000 for family plans. More importantly, COBRA only covers care in the United States, offering no protection for medical needs in Switzerland.
Medicare gap: Americans who have not yet reached age 65 face a significant coverage gap. Medicare does not cover healthcare abroad except in extremely limited circumstances. Americans retiring early to Switzerland must secure private international health insurance until qualifying for Swiss residency and mandatory coverage, or maintain COBRA briefly before transitioning to Swiss insurance. Those over 65 should understand that Medicare Part A (hospital insurance) continues without premiums if you've paid Medicare taxes for 40+ quarters, but Parts B and D require monthly premiums even if you're not using benefits abroad.
Switzerland's mandatory health insurance system operates fundamentally differently from American insurance. Within three months of establishing residence, you must purchase basic coverage (Grundversicherung/assurance de base) from a private insurer. This is not employer-provided insurance—you purchase it individually, and premiums vary by canton, age, and chosen deductible but not by health status. Unlike American insurance, Swiss basic coverage offers standardised benefits defined by federal law, with all insurers covering identical services.
Monthly premiums for basic coverage in 2026 range from CHF 250-450 for adults depending on canton and deductible choice (franchise). Children's premiums run CHF 80-120 monthly. Families pay separately for each member, unlike American family plan structures. The sticker shock is real, but remember that Swiss salaries typically account for this direct cost, unlike American salaries where insurance costs are partially hidden in employer contributions.
Americans accustomed to in-network restrictions will appreciate Swiss insurance flexibility—you choose any licensed doctor or hospital in Switzerland without network limitations. However, Swiss insurance operates on a reimbursement model with annual deductibles (CHF 300-2,500) and 10% co-insurance up to CHF 700 annually. The system emphasises cost transparency and individual responsibility rather than the managed care approach familiar to Americans.
Financial Considerations for American Expats
Moving from the US to Switzerland forces complex decisions about existing retirement accounts, investment portfolios, and banking relationships. American expats in Switzerland navigate more financial complexity than their European counterparts due to US citizenship-based taxation and aggressive enforcement of reporting requirements.
401k and IRA management presents the first major decision point. You have several options: leave accounts with US custodians, roll over to IRAs, or in some cases, transfer to Swiss pension structures. Most financial advisors recommend leaving 401k and IRA accounts in the United States rather than attempting transfers to Swiss institutions. US retirement accounts maintain their tax-advantaged status abroad—you don't pay US taxes on growth until distributions begin, and required minimum distributions (RMDs) follow standard US rules even whilst living in Switzerland.
However, Swiss tax treatment of US retirement accounts creates complications. Switzerland does not automatically recognise the tax-deferred status of 401k or IRA accounts. Under the tax treaty, retirement account growth generally avoids Swiss taxation, but distributions may be taxed by both countries. Roth IRA conversions before relocating can be advantageous—paying US taxes now to secure tax-free qualified distributions later, which Switzerland typically respects under the treaty. This strategy works best for Americans planning permanent moves whilst still in lower US tax brackets.
Brokerage account restrictions shock most American expats. Swiss financial regulations and European MiFID II directives create barriers for Americans trying to open or maintain investment accounts. Many Swiss banks refuse American clients entirely due to FATCA compliance burdens, whilst US brokerages like Vanguard, Fidelity, and Schwab restrict services for expats living abroad. You typically cannot purchase mutual funds or ETFs whilst resident in Switzerland through US brokerages, though you can hold existing positions and trade individual stocks.
This forces Americans into suboptimal solutions: maintaining US brokerage accounts using US addresses (legally questionable), using expensive international brokerage services, or limiting investments to Swiss-domiciled funds (which face punitive US taxation as Passive Foreign Investment Companies under PFIC rules). Interactive Brokers maintains a Swiss entity willing to serve American expats, but options remain limited and expensive compared to domestic US investing.
US dollar banking requires maintaining at least one US bank account for receiving Social Security benefits, managing US-source income, paying US taxes, and maintaining credit history. Online banks like Charles Schwab Bank or Ally Bank accommodate expats better than traditional banks, offering no foreign transaction fees and reimbursing ATM fees globally. Maintaining a US address—whether through family members or mail forwarding services—facilitates this, though disclosure requirements mandate reporting your actual foreign residence.
Credit card management presents another consideration. American credit cards work in Switzerland, but foreign transaction fees (typically 1-3%) add costs. Cards like Chase Sapphire Reserve or Capital One Venture waive these fees. More importantly, maintaining active US credit cards preserves your US credit history, essential if you plan to eventually return or maintain US property. Swiss credit systems operate entirely separately, and you'll build Swiss credit from scratch regardless of excellent US credit scores.
Currency exchange and transfer costs matter significantly. Traditional banks charge 2-3% markups on exchange rates plus wire transfer fees. Specialist services like Wise (formerly TransferWise) or Interactive Brokers offer mid-market rates with minimal fees, potentially saving thousands on large transfers like moving house deposits or retirement savings.
Social Security Coordination
The US-Swiss totalization agreement prevents dual social security taxation and allows combining work credits from both countries to qualify for benefits. Americans working in Switzerland typically pay into the Swiss social security system (AHV/AVS) rather than US Social Security, eliminating the need to pay both systems simultaneously. This matters particularly for short-term assignments—without the totalization agreement, you might pay into a system where you never qualify for benefits.
The agreement coordinates benefits in several ways. First, it eliminates dual coverage—if you work for a US employer temporarily in Switzerland (up to five years), you continue paying US Social Security taxes instead of Swiss AHV. Conversely, Swiss employers pay only into the Swiss system for American employees. This prevents the inefficiency of paying twice whilst potentially qualifying for benefits nowhere.
Second, the agreement allows combining credits to meet minimum eligibility requirements. US Social Security requires 40 credits (typically 10 years of work) for retirement benefits, whilst Swiss AHV requires at least one year of contributions. If you have, say, six years of US work credits and four years of Swiss credits, you can combine them to meet the US 10-year minimum. However, your benefit amount is calculated proportionally based only on actual US earnings—the Swiss credits help you qualify but don't increase the payment amount.
Claiming benefits abroad: Americans living in Switzerland can receive US Social Security benefits without reduction (unlike some countries where non-resident aliens face 25.5% withholding). The Social Security Administration deposits payments into US bank accounts or, with certain limitations, foreign bank accounts. However, you must continue filing US tax returns, and depending on your worldwide income, up to 85% of Social Security benefits may be subject to US federal income tax.
Swiss AHV benefits follow different rules. The Swiss system calculates retirement benefits based on average annual income and contribution years. Americans who work in Switzerland but return to the US can claim Swiss AHV benefits starting at Swiss retirement age (currently 65, rising to 66 by 2029). Benefits are paid internationally, though the modest amounts—maximum monthly AHV benefits approximate CHF 2,500 for individuals with full contribution years—make them supplementary rather than primary retirement income for most American expats.
Medicare and Swiss healthcare do not coordinate. Americans aged 65+ living in Switzerland must decide whether to enrol in Medicare Part B whilst abroad. Part B requires monthly premiums ($174.70 in 2024, increasing annually) but only covers care in the United States. If you plan to return to the US or visit regularly for medical care, enrolling at 65 avoids late-enrolment penalties. However, if you're permanently settled in Switzerland using Swiss health insurance, paying for Medicare Part B you're not using may not make financial sense.
Cost of Living Reality Check
Switzerland consistently ranks among the world's most expensive countries, and Americans relocating need realistic expectations about purchasing power despite higher nominal salaries. Whilst the median Swiss salary exceeds the US median substantially—approximately CHF 85,000 ($93,500) versus $56,000—essential expenses consume a larger portion of income.
| Expense Category | US Average (Boston) | Switzerland (Zurich) | Difference |
|---|---|---|---|
| 1-bed city centre rent | $2,600/month | CHF 2,200 ($2,420/month) | -7% |
| 3-bed city centre rent | $4,200/month | CHF 3,800 ($4,180/month) | -0.5% |
| Monthly health insurance | $450 (employer share additional) | CHF 450 ($495/month) | +10% |
| Groceries (monthly, single) | $400 | CHF 550 ($605/month) | +51% |
| Restaurant meal | $18 | CHF 25 ($27.50) | +53% |
| Public transport pass | $90 | CHF 90 ($99/month) | +10% |
| Childcare (full-time) | $1,800/month | CHF 2,500 ($2,750/month) | +53% |
| International school | $15,000/year | CHF 25,000 ($27,500/year) | +83% |
Housing costs show surprising parity between major Swiss cities and expensive US metros like Boston, San Francisco, or New York. However, Swiss rental apartments typically offer higher quality, better energy efficiency, and often include amenities Americans pay separately for (storage, bike parking, shared laundry). The lack of tipping culture means service industry costs are higher per transaction but eliminate the 18-20% additions Americans budget for restaurants.
Grocery and dining expenses shock most newcomers. Basic items cost 50-60% more than US equivalents—a gallon of milk runs CHF 6-7 ($6.60-7.70) versus $3.50-4.00 in the US, whilst chicken breasts cost CHF 30-35 per kilogram ($15-16 per pound) versus $3-4 per pound. Dining out is particularly expensive, with casual restaurant meals starting at CHF 20-25 ($22-27.50) before drinks. The bright side: food quality is exceptional, and eating at home rather than dining out becomes financially attractive even for busy professionals.
For families, childcare and education represent massive costs. Swiss public schools are excellent and free, but operate on schedules incompatible with dual-income families—children often return home for lunch, and school hours end by 16:00. Childcare to bridge these gaps costs CHF 100-150 ($110-165) per day, making full-time care for one child CHF 2,000-3,000 monthly. American expat families often choose international schools offering familiar curricula and English instruction, but fees of CHF 25,000-35,000 annually per child quickly consume salary increases.
Transportation costs favour Switzerland if you embrace the public transport system. Monthly passes covering entire cantons cost CHF 70-90 ($77-99), whilst the Swiss Travel Pass provides unlimited travel nationwide for CHF 245 ($270) monthly. Car ownership is expensive—insurance runs CHF 1,500-3,000 annually, petrol costs CHF 1.80-2.00 per litre ($7-8 per gallon), and parking in cities ranges from CHF 30-50 daily. Most American expats adjust to car-free urban living, discovering that Swiss public transport exceeds any US equivalent for reliability and coverage.
The bottom line: Swiss salaries are higher, but you need 20-30% more gross income to maintain equivalent purchasing power to mid-tier US cities, and 40-50% more to match quality of life in lower-cost US regions. However, this calculation omits significant Swiss advantages—five weeks minimum annual holiday, excellent public services, world-class healthcare, and superior work-life balance—that don't appear in cost comparisons but substantially affect life quality.
For detailed cost breakdowns by canton and city, see our comprehensive Cost of Living in Switzerland 2026 guide.
Cultural Adjustments Americans Should Expect
Moving from the US to Switzerland involves more than logistical challenges—cultural differences affect daily life, workplace dynamics, and social integration in ways Americans often underestimate. Swiss culture values precision, privacy, and predictability over the flexibility, friendliness, and informal networking that characterise American social norms.
Workplace culture differs markedly from American corporate environments. Swiss business operates more formally—colleagues use surnames and formal pronouns (Sie/vous) for months or years before transitioning to first names. The American habit of immediate informality and assumed friendliness strikes Swiss colleagues as presumptuous or unprofessional. Meetings start precisely on time, agendas are followed religiously, and decisions emerge from consensus-building rather than top-down directives.
Work-life boundaries are sacred in Switzerland. The American expectation of responding to emails evenings and weekends is largely absent—Swiss colleagues disconnect after hours and during holidays without guilt. This extends to management expectations: whilst American employers may praise "going above and beyond," Swiss employers expect efficient work within contracted hours. The cultural assumption is that working excessive hours indicates poor planning or capability rather than dedication.
Social integration challenges Americans accustomed to casual friendship formation. Swiss social circles form early through school, military service, and local clubs, creating tight-knit groups less open to newcomers. Americans expecting quick friendships through workplace socialising or neighbourhood interactions often find Swiss acquaintances polite but distant. Integration requires patience, learning local languages, and joining clubs or hobby groups—the primary Swiss method for expanding social circles.
Practical considerations like Sunday closures frustrate Americans used to 24/7 commercial availability. Virtually all shops close Sundays, and even Saturday hours are limited. Running Sunday errands is impossible, requiring weekly planning unfamiliar to Americans accustomed to late-night supermarket runs. Noise regulations prohibit activities like lawn mowing on Sundays and after 20:00 on weekdays—violations prompt neighbour complaints or fines.
"The first six months, I thought Swiss people were cold and unfriendly. A year in, I realised they're just private and value earned trust over instant intimacy. Once you're inside someone's circle, the friendships are deeper and more reliable than the casual acquaintances I called friends in the US. It just takes more time and effort than I expected." — Jennifer M., American expat in Basel since 2019
Language presents ongoing challenges even in English-friendly cities like Zurich. Whilst educated Swiss speak excellent English professionally, social life and local administration operate in Swiss German, French, or Italian depending on canton. Americans who neglect learning local languages face persistent integration barriers and reduced quality of life. Swiss German particularly frustrates learners—the spoken dialect differs substantially from standard German taught in courses, requiring separate study.
Bureaucratic precision demands adjustment. Swiss administration expects perfect paperwork, advanced appointments, and adherence to regulations Americans might consider overly rigid. The permit system, insurance requirements, and tax filings require organisation and attention to detail. However, once you understand the system, it functions predictably and efficiently—a contrast to American bureaucracies where outcomes can seem arbitrary despite less stringent requirements.
American Community Resources in Switzerland
Despite integration challenges, Switzerland hosts active American expat communities offering support, networking, and cultural connection. These resources help ease transition stress whilst maintaining ties to American culture and facilitating practical knowledge sharing.
The American International Club of Zurich and similar organisations in Geneva, Basel, and Bern provide networking events, cultural activities, and practical support for newly arrived Americans. Membership typically costs CHF 80-150 annually and includes access to events, online forums, and mentorship programmes pairing newcomers with established expats.
American Women's Clubs operate in major Swiss cities, offering social connection and integration support primarily (though not exclusively) for women. These clubs organise cultural outings, language exchanges, and community service projects whilst maintaining American holiday celebrations like Thanksgiving potlucks and Fourth of July events that help combat homesickness.
The US Embassy in Bern provides critical services including passport renewal, consular reports of birth abroad for children born in Switzerland, and notary services. The embassy also maintains updated information on US tax obligations, voting procedures, and emergency assistance. Regional consulates in Zurich provide similar services for northeastern Switzerland.
American schools serve expat families seeking US-based curricula. The Zurich International School, International School of Geneva, and American International School of Zurich offer American or International Baccalaureate programmes, though fees range from CHF 25,000-35,000 annually. These schools create American peer groups for children but can limit integration into Swiss society—a trade-off families must consider carefully.
Online communities like "Americans in Switzerland" Facebook groups and Reddit's r/Switzerland provide practical advice, service recommendations, and emotional support. These platforms prove particularly valuable for navigating bureaucratic challenges, finding English-speaking service providers, and understanding American-specific concerns like tax preparation or maintaining US banking relationships.
Frequently Asked Questions
Can I move to Switzerland without a job offer?
No, with rare exceptions. Americans need employer sponsorship for work permits unless married to a Swiss citizen, independently wealthy with substantial investments (cantonal approval required), or retiring with significant pension income demonstrating financial self-sufficiency. Job-seeking visas don't exist for Americans. You must secure employment before relocating, and your employer must obtain permit approval before you can legally enter Switzerland to work.
Will I pay more or less tax than in the United States?
This depends on your income level, canton of residence, and US state of origin. Americans from high-tax states like California or New York may find Swiss tax burdens comparable or even slightly lower at high income levels. Those from no-income-tax states like Texas or Florida will definitely pay more in Switzerland. However, you receive better public services, infrastructure, and social benefits for Swiss taxes than most US states provide. Tax planning requires professional advice considering both jurisdictions.
How do I maintain my US credit score whilst living in Switzerland?
Keep at least one US credit card active with regular charges and timely payments. Use a reliable US address (family member or mail forwarding service) for statements. Some Americans keep a small balance in US bank accounts with automatic credit card payments to maintain activity. Note that Swiss credit systems are entirely separate—you'll build Swiss credit history from scratch regardless of excellent US credit.
Can I bring my American car to Switzerland?
Technically yes, but practically inadvisable. Import duties, modification costs to meet Swiss standards (different headlight patterns, emission controls), and left-hand drive orientation make this expensive and impractical. Sell your US vehicle before moving and purchase in Switzerland if needed, or rely on excellent public transport. Short-term visitors can use US-registered vehicles temporarily but face restrictions and insurance complications.
What happens to my 401k if I move to Switzerland?
Nothing, unless you choose to make changes. Leave your 401k with the US custodian—it maintains tax-advantaged status and you avoid early withdrawal penalties. Switzerland generally respects the tax-deferred nature of US retirement accounts under the tax treaty, though you should consult a cross-border tax advisor. You can continue managing the account online and take distributions in retirement following normal US rules, though currency exchange considerations apply.
How difficult is it to get permanent residency in Switzerland as an American?
Challenging but achievable with patience. Americans need ten years of continuous residence to qualify for C permits (permanent residence), though bilateral agreements sometimes reduce this to five years in specific circumstances. Unlike citizenship (which requires 10+ years and cultural integration tests), permanent residence follows automatically after meeting time requirements, maintaining stable residence, and demonstrating integration through language ability and respect for Swiss laws. You must continuously hold valid permits during the qualifying period—permit lapses reset the clock.
Conclusion
Moving from the US to Switzerland offers Americans exceptional quality of life, career opportunities, and stability in exchange for navigating complex immigration requirements, dual tax systems, and cultural adjustments. Success requires thorough preparation—understanding the US-Swiss tax treaty, securing employment before relocating, preparing for higher living costs despite higher salaries, and committing to cultural and linguistic integration.
The Americans who thrive in Switzerland are those who embrace difference rather than expecting Swiss life to replicate American norms. You'll discover that directness replaces American-style friendliness, precision supplants flexibility, and privacy trumps openness. These aren't deficiencies but cultural values offering different benefits—reliability, efficiency, and depth over breadth in relationships.
Financial planning proves critical. Engage cross-border tax professionals before moving, maintain US banking relationships and credit history, and understand how retirement accounts, Social Security, and healthcare coordination work between countries. The administrative burden of American citizenship-based taxation never disappears, but proper planning minimises complications and costs.
Switzerland rewards those who invest effort in integration. Learn the local language, join clubs and community organisations, and participate in Swiss civic life. The American community provides valuable support during transition, but genuine quality of life emerges from building bridges to Swiss society rather than retreating into expat enclaves. Moving from the US to Switzerland is not a simple relocation—it's a long-term commitment to building a new life whilst maintaining ties to your American identity and obligations.
