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Information (AEOI) ) About Foreign Financial Accounts
Information (AEOI) ) About Foreign Financial Accounts
Caveats
1. Residents of certain countries are still required to report foreign bank accounts on
their own initiative
But this can be circumvented by declaring yourself a non-resident and moving
to a country that does not require self-reporting –with exception of US
citizens, who must renounce their citizenship to do this.
2. US citizens/resident aliens
Still subject to a separate set of rules (FATCA4), under which foreign financial
institutions around the world are required to disclose US clients5’ accounts to
the US government/IRS and their own domestic tax authorities.
Differences between FATCA and CRS:
o CRS was based on the FATCA (which came into force in 2014)
arrangements
1
An account maintained by a financial institution (which includes custodial institutions).
2
Includes custodial institutions, depository institutions, investment entities, and specified insurance
companies.
3
OECD allows the participating countries to determine what accounts are reportable. "The term
"reportable account" means a [Jurisdiction A] reportable account or a [Jurisdiction B] reportable
account, depending on the context, provided it has been identified as such pursuant to due diligence
procedures, consistent with the Annex, in place in [Jurisdiction A] or [Jurisdiction B]."
4
US Foreign Account Tax Compliance Act (FATCA)
5
Both US citizens and residents, including resident aliens.
o CRS requires financial institutions in participating institutions to report
on almost all accounts held by non-residents of the reporting country –
in contrast, FATCA requires financial institutions to report foreign-
held accounts of US citizens and residents.