New Zealand super funds and KiwiSaver accounts remain in the sights of United States tax authorities, after some loosening of rules aimed at American tax dodgers.
Legislation passed two years ago was to have compelled foreign financial institutions to provide information about United States citizens to its Internal Revenue Service.
The law prompted a worldwide backlash from the financial services industry, which complained it would cost hundreds of millions of dollars to comply with the rules.
But an international deal brokered with American authorities within the past week has meant some institutions will be exempt from the global dragnet.
A tax partner at PricewaterhouseCoopers, Mark Russell, says building societies, credit unions and other non-bank deposit-takers have been included in the carve-out.
"The group that's probably the most disappointed is the KiwiSaver providers and superannuation providers who would have been hoping to be carved out.
"There are quite substantial carve-outs for superannuation-style products, but the criteria that are required to be met won't be able to be met, as they are currently drafted by New Zealand funds. Basically, because people pay into superannuation out of their tax-paid earnings rather than out of pre-tax earnings, they won't be able to qualify.
"I suspect the New Zealand superannuation and KiwiSaver industries will be wanting to make submissions to get those rules changed to bring themselves within those exemptions.
"From a policy point of view, it makes sense for them to be excluded - because if you were trying to avoid US tax, it doesn't make sense to do that by starting a KiwiSaver."
Mr Russell says if funds can't get exemptions, it could cost them up to tens of millions of dollars to comply with the rules.