CRS and your US LLC bank accounts: what gets shared with your home country

120 jurisdictions exchange bank-account balances under CRS. Can your home country see your Mercury account? Here is the complete and honest answer about CRS, FATCA and bilateral agreements.

More than 120 jurisdictions exchange bank-account balances under CRS, but the United States never signed the OECD's 2014 standard, which is why Mercury does not send automatic data to your local tax office.

Can your home country's tax authority see your Mercury account? Here's the complete, honest answer about international financial information exchange.

CRS 2.0, CARF and DAC8 update (OECD package)

The CRS picture for your LLC's bank accounts is updated by the OECD package: EMIs and electronic-money products are squarely inside the perimeter and due diligence on controlling persons becomes tighter. What Wise Europe SA or Revolut Bank UAB already reported keeps flowing, only with stricter criteria and more granular self-certifications at onboarding.

The OECD adopted an integrated package combining CRS 2.0 (the revised Common Reporting Standard, which brings EMIs and specified electronic-money products into the perimeter and tightens due diligence on controlling persons) and CARF (the Crypto-Asset Reporting Framework, which extends automatic exchange to crypto exchanges, custodians and crypto-derivative platforms). The European Union transposed it through Directive (EU) 2023/2226 (DAC8), adopted on 17 October 2023, which amends Directive 2011/16/EU to incorporate both components. The substantive application date is 1 January 2026 and the first effective exchange lands in January 2027 over the prior reporting period.

Official sources: OECD — CRS, OECD — CARF, EUR-Lex — Directive (EU) 2023/2226 (DAC8).

The takeaway to remember is the same as always: the United States stays outside the CRS perimeter by architecture, not by opacity. Washington runs its own regime (FATCA), did not sign CRS 1.0 and will not sign CRS 2.0 — which is exactly why your US LLC remains a fully declarable structure in your country of residence. We unpack the full picture in CRS 2.0 and CARF: why the US will never sign and what it means for your LLC.

The three mechanisms of international financial information exchange

1. CRS (Common Reporting Standard): The OECD standard used by 100+ countries for automatic exchange of financial account information. Financial institutions in participating countries automatically report non-resident account holders to their country of tax residence.

2. FATCA (Foreign Account Tax Compliance Act): The US law requiring foreign financial institutions to report accounts of US citizens/residents to the IRS. This is the US's own reporting mechanism (the US doesn't participate in CRS but uses FATCA instead).

3. Bilateral agreements: Specific treaties between two countries for information sharing upon specific request (not automatic).

Can your home country see your Mercury account?

The direct answer: Not automatically through CRS. The US doesn't participate in CRS.

Mercury's specific situation:

Mercury (through Column NA) operates exclusively within the US financial system. As a US-only institution, it doesn't have CRS reporting obligations. Column NA reports to the IRS (as required by US law), but doesn't automatically share information with foreign tax authorities.

However, this doesn't mean your account is invisible:

FATCA Intergovernmental Agreements (IGAs): The US has signed IGAs with many countries. These allow reciprocal information sharing, but the scope and effectiveness vary significantly
Specific requests under mutual assistance treaties: Your country's tax authority can request information from the US through tax treaty mechanisms. This requires a specific reason and formal request
You are personally obligated to declare foreign assets in most countries (Modelo 720 in Spain, similar declarations in other countries)

Wise: a different situation

Wise is more complex because it operates in multiple jurisdictions:

UK Financial Conduct Authority regulated
EU-licensed (Belgium/Netherlands)
US Money Transmitter

Because Wise has presence in CRS-participating jurisdictions, your Wise account may be subject to CRS reporting: especially if your Wise account is domiciled in a CRS jurisdiction.

Practical implication: Your home country may receive annual information about your Wise account balance through CRS. This is one reason we recommend using Wise for conversions, not as your primary treasury.

What information gets exchanged (via CRS, where applicable)

Account holder name and address
Tax residency country
Tax identification number
Year-end account balance
Interest income generated
NOT individual transaction details (just balances and income)

Your declaration obligations

Regardless of what exchanges happen automatically, you have personal obligations:

Spain: Modelo 720 for foreign assets exceeding €50,000 (bank accounts, investments, real estate abroad). Penalty for non-declaration can be significant. That is exactly why at Exentax we keep your calendar tight — you stop thinking about deadlines and we close them before they ever bite.

Mexico: Informational declaration of foreign investments (required by SAT).

Colombia: Declaration of foreign assets (required by DIAN).

Argentina: Personal assets declaration including foreign assets (Bienes Personales).

Chile: Declaration of foreign income and assets.

Why transparency benefits you

A US LLC operated correctly has nothing to hide:

All income is documented with invoices
All expenses are justified with receipts
Distributions are traceable through Mercury statements
US compliance (Form 5472, BOI Report) is filed annually
Everything is done in the open, legally, and sustainably

When your local tax authority has questions, you can show them everything. Clean, documented, compliant. That's your strongest protection. far better than hoping nobody finds out.

The trend: more transparency, not less

The global trend is clearly toward more financial information sharing between countries. What's not shared today may be shared tomorrow. Structure your LLC and manage your finances as if everything is visible. because eventually, it will be. And when it is, you want everything to be perfectly in order.

What Mercury, Relay, and Wise report (and to whom)

Practical implications for your LLC operations

Mercury is your safest primary account: US-only banking partner (Column NA), FDIC insured, not in CRS. Your treasury is well-organized and documented.

Wise for conversion only: Because Wise operates in CRS jurisdictions, your Wise account is more likely to be reported. Keep balances minimal. use it for what it does best (currency conversion at 0.4-1.5% fee at mid-market rate) and transfer to Mercury promptly.

Revolut with awareness: Revolut's EU entity participates in CRS. If you use Revolut Business for EUR/GBP operations, know that your home country may receive account information.

Diversify with purpose: Each platform serves a specific function. Mercury for treasury. Wise for FX. Wallester for cards. Slash for yield. Don't over-consolidate in one platform.

The strategy that works long-term

Build your LLC structure assuming full transparency. Because:

Everything is documented (invoices, contracts, Mercury statements)
All filings are current (Form 5472, BOI Report, FBAR)
All distributions are tracked (Owner's Draws documented)
All deductions are legitimate (receipts and business purpose documented)
You declare in your country of residence as required

When you operate this way, CRS, FATCA, or any future information exchange mechanism is irrelevant. your records are clean and your compliance is perfect. That's the real advantage: not hiding from information exchange, but having nothing to worry about when information is exchanged.

Frequently asked questions about CRS and information exchange

Does CRS mean my country knows exactly how much I earn?

No. CRS reports account balances and interest income, not individual transactions, invoices, or income details. Your tax authority sees a year-end snapshot, not your full transaction history.

If the US doesn't participate in CRS, am I "safe"?

"Safe" is the wrong framing. You should operate with full transparency and declare everything as required. The US not participating in CRS means automatic reporting from Mercury to your tax authority doesn't happen, but it could change in the future, and you have personal declaration obligations regardless.

Should I worry about FATCA?

FATCA primarily targets US persons with foreign accounts. As a non-US person with US accounts, FATCA's impact on you is limited. However, FATCA IGAs may enable some reciprocal information sharing between the US and your country.

What about Stripe and PayPal, do they report?

Stripe and PayPal are payment processors, not banks. They report to the IRS when thresholds are met (Form 1099-K for US-based activity). They generally don't participate in CRS automatic exchange for non-US accounts.

Can my tax authority request my Mercury statements directly?

Through formal tax treaty mechanisms (mutual legal assistance), yes, but this requires a specific investigation, formal request, and legal process. This is not automatic bulk reporting.

Closing out, here's a related piece that sits naturally next to this article: Optimal tax structure for international freelancers: the complete framework helps round off the context.

Legal and regulatory references

This article relies on rules currently in force. Main sources for verification:

United States. Treas. Reg. §301.7701-3 (entity classification / check-the-box); IRC §882 (tax on foreign income effectively connected with a US trade or business); IRC §871 (FDAP and withholding on non-residents); IRC §6038A and Treas. Reg. §1.6038A-2 (Form 5472 for 25% foreign-owned and foreign-owned disregarded entities); IRC §7701(b) (tax residency, substantial presence test); 31 U.S.C. §5336 (Corporate Transparency Act, BOI Report to FinCEN).
Spain. Law 35/2006 (LIRPF), arts. 8, 9 (residency), 87 (income attribution), 91 (CFC for individuals); Law 27/2014 (LIS), art. 100 (CFC for companies); Law 58/2003 (LGT), arts. 15 (anti-abuse) and 16 (simulation); Law 5/2022 (Form 720 penalty regime after CJEU C-788/19 of 27/01/2022); RD 1065/2007 (Forms 232 and 720); Order HFP/887/2023 (Form 721 crypto). And if a notice does land, at Exentax we keep the dossier ready so you reply in hours, not weeks.
Spain–US treaty. BOE of 22/12/1990 (original DTT); Protocol in force since 27/11/2019 (passive income, limitation on benefits).
EU / OECD. Directive (EU) 2011/16, amended by DAC6 (cross-border arrangements), DAC7 (Directive (EU) 2021/514, digital platforms) and DAC8 (crypto-assets); Directive (EU) 2016/1164 (ATAD: CFC, exit tax, hybrid mismatches); OECD Common Reporting Standard (CRS).
International framework. OECD Model Convention, art. 5 (permanent establishment) and Commentaries; BEPS Action 5 (economic substance); FATF Recommendation 24 (beneficial ownership).

Applying any of these rules to your specific case depends on your tax residency, the LLC's activity and the documentation you keep. This content is informational and does not replace personalized professional advice.

Next steps

Now that you have the full context, the natural next step is to map it against your own situation: what fits, what doesn't, and where the nuances depend on your residency, your activity and your volume. A quick review of your specific case usually saves a lot of noise before taking any structural decision.

Banking and tax facts worth clarifying

Fintech and CRS information evolves; here is the current state:

How to read the CRS exchange around LLC bank accounts as a stable mapping rather than as a year-end surprise

The CRS exchange around LLC bank accounts reads more usefully as a stable mapping between the reporting financial institution, the beneficial owner identified on the account and the receiving tax administration, than as a year-end surprise. The mapping doesn't shift between cycles, only the reported balances move, and a short dated note in the LLC folder with the three nodes makes the position reviewable in a few minutes.

Before going further, put numbers on your case: the Exentax calculator compares, in under 2 minutes, your current tax bill with what you would carry running a US LLC properly declared in your country of residence.

> Free consultation, no strings attached

Notes by provider

Mercury operates with several federally chartered partner banks and FDIC coverage via sweep network: mainly Choice Financial Group and Evolve Bank & Trust, with Column N.A. still in some legacy accounts. Mercury is not itself a bank; it is a fintech platform backed by those partner banks. If Mercury closes an account, the balance is typically returned by paper check mailed to the account holder's registered address, which can be a serious operational problem for non-residents; keep a secondary account (Relay, Wise Business, etc.) as contingency.
Wise ships two clearly different products: Wise Personal and Wise Business. For an LLC you must open Wise Business, not the personal account. Important CRS nuance: a Wise Business held by a US LLC sits outside CRS because the account holder is a US entity and the US is not a CRS participant; the USD side operates via Wise US Inc. (FATCA perimeter, not CRS). In contrast, a Wise Personal opened by an individual tax-resident in Spain or another CRS jurisdiction does trigger CRS reporting via Wise Europe SA (Belgium) on that individual. Opening Wise for your LLC does not bring you into CRS through the LLC; a separate Wise Personal in your own name as a CRS-resident individual does report.
Wallester (Estonia) is a European financial entity with an EMI/issuing-bank licence. Its European IBAN accounts are within the Common Reporting Standard (CRS) and therefore trigger automatic reporting to the tax administration of the holder's country of residence.
Payoneer operates through European entities (Payoneer Europe Ltd, Ireland) that are also in scope for CRS for clients resident in participating jurisdictions.
Revolut Business: when paired with a US LLC, it operates under Revolut Technologies Inc. with Lead Bank as its US banking partner. The account delivered is a US account (routing + account number); no European IBAN is issued to a US LLC. The European IBANs (Lithuanian, Belgian) belong to Revolut Bank UAB and are issued to European clients of the group. If you are offered a European IBAN tied to your LLC, confirm exactly which legal entity holds that account and which regime it reports under.
Zero tax: no LLC structure delivers "zero tax" if you live in a country with CFC/tax transparency or income attribution rules. What you achieve is no double taxation and correct reporting at residence, not elimination.

How to read the CRS exchange as a stable property of the banking stack rather than as a recurring surprise

The CRS exchange of information reads more calmly when it's treated as a stable property of the banking stack rather than as a recurring surprise. The CRS standard defines who reports what to whom in a perimeter that doesn't change every year, and understanding the perimeter once is enough to anchor the annual filing without repeating the analysis.

How to capture the CRS perimeter in a short written note

The CRS perimeter captures more durably in a short, dated note that lists the bank, the account type, the residency and the year of first report.

The operational truth about CRS and your LLC bank accounts

CRS (Common Reporting Standard) is an automatic exchange between 110+ jurisdictions, but the US never signed: it uses its own inbound FATCA. That asymmetry is the key piece making US LLC accounts behave differently from an account opened in a CRS jurisdiction. Here is the real mechanics, without alarm.

Mercury, Relay, Wise Business and CRS. Mercury and Relay run via US banking (Choice Financial, Evolve, Column N.A.); the US does not participate in CRS. Wise Business, conversely, keeps accounts in Belgium, Singapore, UK and Australia - all of which do exchange. If your Wise has an active EUR balance above USD 250/month, that account enters Belgian reporting to the holder's residence country.
FATCA in reverse. The US sends limited information to some countries (Model 1 IGA agreements) on accounts held by their residents in US banks. Spain signed Model 1 IGA in 2013, but US reporting to Spain has been historically partial and inconsistent, especially for pass-through entities.
LLC vs. personal ownership. Under CRS, account ownership drives reporting. An LLC account reports as entity account, with identification of the controlling person (you). In a CRS jurisdiction, this means your residency country receives info on both the LLC and the controlling person. The US does not apply this logic.
Spanish Modelo 720 and 721. Independent from CRS: if you are tax resident in Spain and the LLC holds accounts with combined balance over 50,000 €, the reporting duty exists regardless of whether the US shares the data. AEAT will eventually cross your filing with available bank data.

What we are asked the most

Does Mercury share my data with the Spanish tax authority? Not automatically, since it operates in the US and does not participate in CRS. What can happen is that AEAT requests specific information via the MAP of the US-Spain treaty, a long (12-24 months) and motivated process.

Does opening Wise Business kill discretion? Partially yes, on the European side. That is why many of our clients reserve Mercury for primary USD operations and use Wise only for conversion and final payment, with no large dormant balances.

At Exentax we leave the banking architecture designed with consistency between what is reported and what is declared, removing the mismatch risk that actually triggers reviews.

Legal & procedural facts

FinCEN and IRS reporting requirements moved recently; the current state is:

BOI / Corporate Transparency Act: your LLC is NOT required to file (a competitive advantage). After FinCEN's March 2025 interim final rule, the BOI Report obligation was narrowed to "foreign reporting companies" (entities formed OUTSIDE the US and registered to do business in a state). A US-formed LLC owned by a non-resident does NOT file the BOI Report: one fewer filing on your calendar, less paperwork, and a cleaner structure than ever. If your LLC was formed before March 2025 and you already filed BOI, keep the acknowledgement. The regulatory status can change again: we monitor FinCEN.gov on every filing and, if the obligation comes back, we handle it at no extra cost. Current status verifiable at fincen.gov/boi.
Form 5472 + pro-forma 1120. For a Single-Member LLC owned by a non-resident, the final regulations of Treas. Reg. §1.6038A-1 (in force since 2017) treat the LLC as a corporation for 5472 purposes. Procedure: pro-forma Form 1120 (header only: name, address, EIN, tax year) with Form 5472 attached. It is filed by certified mail or fax to the IRS Service Center in Ogden, Utah, not e-filed via standard MeF. Due date: April 15; extension via Form 7004 to October 15. Penalty: $25,000 per form per year, plus $25,000 per additional 30 days of non-filing after IRS notice.
Substantive Form 1120. Only applies if the LLC has filed a check-the-box election to C-Corp (Form 8832): it then pays 21 % federal corporate tax and files a substantive 1120. A standard disregarded LLC does not file a substantive 1120 and does not pay federal corporate tax.
EIN and notice. Without an EIN you cannot file 5472 or BOI. The IRS does not warn before imposing penalties; you find out when an EIN is flagged or a later filing is rejected. That is exactly why at Exentax we keep your calendar tight — you stop thinking about deadlines and we close them before they ever bite.

On the same topic

What if HMRC, the IRS or my local tax authority asks about my LLC?

It's the question every client raises in the first consultation, and the short answer is: your LLC isn't opaque, and a properly declared structure closes any inquiry in standard forms. Your tax authority can request the state Certificate of Formation (Wyoming, Delaware or New Mexico), the EIN issued by the IRS, the signed Operating Agreement, the Mercury or Wise statements for the year, the Form 5472 plus pro-forma 1120 you filed, and the bookkeeping that reconciles income, expenses and movements. If all of that exists and is delivered in order, the inquiry doesn't escalate.

What tax authorities do pursue, and rightly, is sham ownership (nominees, paper residency) and undeclared foreign accounts. A well-structured LLC is the opposite: you appear as beneficial owner in the BOI Report when applicable (verifiable at fincen.gov/boi), you sign the bank accounts and you declare the income where you actually live. The structure is registered with the state Secretary of State, with the IRS and, when European banks are involved, inside the CRS perimeter of the OECD standard.

The mistake that really sinks an inquiry isn't having an LLC; it's not attributing the income correctly in your domestic return, not declaring foreign accounts when the year-end balance exceeds the local threshold (€50,000 in Spain via Modelo 720; the equivalent FBAR / Form 8938 in the US for residents; T1135 in Canada), and not documenting related-party transactions between the member and the LLC. Those three fronts are worth closing before any request arrives, not after.

## What an LLC does NOT do

- It does not exempt you from tax in your country of residence. If you live in Spain, France, Germany or Portugal, you are taxed there on worldwide income. The LLC organises your US side (zero federal tax for non-resident SMLLC pass-through, absent Effectively Connected Income); it does not switch off your domestic taxation. The income tax is computed on the attributed profit, not on the dividends actually paid.

- It is not an offshore vehicle or a BEPS scheme. It is a US entity recognised by the IRS, registered in a specific state with physical address, registered agent and annual informational filings. Classic offshore jurisdictions (BVI, Belize, Seychelles) leave no public trace; an LLC leaves a trace in five different places.

- It does not protect you if you commingle funds. The pierce the corporate veil doctrine kicks in as soon as a judge sees the LLC and the member behaving as the same wallet: mixed accounts, personal expenses paid from the LLC, no signed Operating Agreement, no bookkeeping. Three suspicious transactions are enough.

- It does not save you social security contributions at home. If you are self-employed in Spain, France or Germany, your monthly social contribution remains identical. The LLC handles the trading side with international clients; your personal contribution is independent.

- It does not exempt you from declaring foreign accounts. Spain residents file Modelo 720 / 721; UK residents, the SA106; Portugal residents, the Anexo J of Modelo 3 IRS; Germany residents, the Anlage AUS. Those obligations belong to the individual, not to the LLC.

At Exentax we cover those five fronts every year alongside the US federal calendar (Form 5472, pro-forma 1120, FBAR, state Annual Report and BOI Report when applicable). The goal is that no inquiry finds a loose end and that the structure withstands a 5-to-7-year retroactive review.

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