What Are FATCA and CRS, and Will the US Report My Account Back Home?

Not through CRS. The United States never signed the Common Reporting Standard. All 126 jurisdictions that did sign it, including Mexico, Colombia, Spain, Panama and Peru, exchange account data with each other automatically. The US sits outside that system and exchanges under FATCA instead, on its own terms.

That single fact explains most of the confusion around this question. People assume there is one global reporting network and that a US company account is inside it. There are two networks, they were built for different purposes, and the US belongs to only one of them: the one it wrote.

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01What Is CRS, and Which Countries Actually Signed It?

CRS is the OECD's Common Reporting Standard, a multilateral agreement under which tax authorities send each other financial account information once a year without anyone asking. The signatory list runs to 126 jurisdictions as of 13 March 2025.

Every market our clients come from is on it, and has been for years. The dates matter because they tell you how long your home tax authority has been receiving this data:

• Argentina: signed 29 October 2014
• Colombia: signed 29 October 2014
• Mexico: signed 29 October 2014
• Spain: signed 29 October 2014
• Chile: signed 4 June 2015
• Costa Rica: signed 3 June 2015
• Brazil: signed 6 October 2016
• Uruguay: signed 2 November 2016
• Panama: signed 15 January 2018
• Ecuador: signed 29 October 2018
• Peru: signed 19 November 2020

02Why Is the United States Not on That List?

Because it had already built its own system. FATCA became law in 2010, four years before CRS opened for signature, and it obliges foreign financial institutions to report accounts held by US persons directly to the IRS. Having secured what it wanted bilaterally, the US did not join the multilateral standard.

The practical consequence is an asymmetry, and it is worth stating plainly rather than treating as a loophole. FATCA is built to bring information into the United States. CRS is built so that everyone exchanges with everyone. A country that participates in the first is not automatically covered by the second.

03Does My Home Country Already See My US Company Account?

Often yes, but through a different door than people expect. If your country has a FATCA intergovernmental agreement with the US, information can move under that agreement, and separately the US has bilateral tax treaties and information exchange agreements that allow requests. What does not happen is the automatic annual CRS feed.

The distinction that matters for planning is between automatic and on request. CRS data arrives every year whether or not anyone is looking at you. The US channels are narrower, slower, and in several cases require your tax authority to ask for something specific.

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04Does This Change What I Owe?

No. Reporting and liability are separate questions, and conflating them is where people get into trouble. Whether your account is visible to your home tax authority has no effect on what you owe it, or on what you owe the IRS under your US entity's own filing obligations.

A foreign-owned US LLC still files its Form 5472 and pro forma 1120 whether or not any country exchanges anything, and the penalty for missing it is 25,000 dollars. Visibility is not the thing that creates the obligation. The obligation was always there.

05What Should I Actually Do With This?

Assume your home country will find out, and structure so that it does not matter. That is the only posture that survives a rule change, and rules in this area have changed twice in fifteen years.

Concretely: know which of your accounts are held personally and which are held by the US entity, because the two are reported through different mechanisms. Keep your US company's filings current so that nothing on the US side is outstanding. And confirm with an adviser in your own country what your local declaration requires, because that is the obligation CRS actually enforces.

If you would like this mapped against your own structure and your own country's agreements rather than in general terms, start here and we will walk through it with you.