US bank accounts: what gets reported and how to organise your LLC

2014 CRS. Mercury, Wise US Inc, Slash and Relay are outside CRS because the US doesn't participate. FATCA is bilateral and doesn't auto-export account data to Europe. Wallester does report in Europe. How a well-structured LLC organises its reporting.

The US never signed the 2014 CRS, and FATCA only exchanges with Spain — under Model 1 IGA — partial information on individual accounts, not on your LLC's operating account.

"Does Mercury tell my tax authority how much money I have?" This is the question we receive most often. Here's the complete, honest answer. no sugarcoating, no fear-mongering.

CRS 2.0, CARF and DAC8 update (OECD package)

The honest answer about what US banks report does not change with the OECD package: CRS 2.0 widens the perimeter outside the United States, but the domestic US banking system still does not report to your home tax authority for the simple reason that the United States is not — and will not be — a CRS jurisdiction.

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 reporting

1. CRS (Common Reporting Standard): Automatic exchange between 100+ countries for non-resident accounts. The US is notably absent from CRS.

2. FATCA (Foreign Account Tax Compliance Act): US law requiring foreign financial institutions to report accounts of US citizens/residents to the IRS. The US has its own system separate from CRS.

3. Bilateral agreements (IGAs): Country-specific treaties for information exchange. The US has signed Intergovernmental Agreements with many countries under FATCA.

What happens with your Mercury account?

Mercury is a US fintech using Column NA as its banking infrastructure. It operates exclusively within the US financial system.

Does Mercury report to the IRS? Yes. like any US financial institution, Mercury/Column NA complies with US reporting obligations. This includes 1099 forms when applicable.

Does Mercury report to your home tax authority? Not directly through CRS (the US doesn't participate). However:

The US and your country may have a FATCA IGA allowing some reciprocal information sharing
Your country's tax authority can request information specifically through tax treaty mechanisms
Information exchange is possible but not automatic in the CRS sense

The practical reality: currently, automatic reporting from US financial institutions to foreign tax authorities is significantly less comprehensive than CRS reporting from European institutions. But this may change. the trend is toward more transparency.

What about Wise?

Wise is more complex. As an EMI with presence in multiple jurisdictions (UK, EU, US), Wise has CRS reporting obligations in CRS-participating countries.

Practical implication: If your Wise account is associated with a CRS-participating jurisdiction, your home country may receive annual summary information about your account.

What gets reported via CRS: Year-end balance, income generated (interest). NOT individual transactions.

And Relay?

Relay uses Thread Bank as its banking infrastructure. Similar to Mercury, it operates within the US system. Same situation as Mercury regarding reporting.

And Slash?

Slash is a treasury management platform. Its reporting obligations depend on the specific banking infrastructure it uses. Similar considerations as Mercury apply.

The Modelo 720 and similar obligations

Regardless of what gets automatically reported, most countries require you to declare foreign assets:

Spain: Modelo 720 for foreign assets exceeding €50,000. This is YOUR obligation, not the bank's. Non-compliance carries penalties. And if a notice does land, at Exentax we keep the dossier ready so you reply in hours, not weeks.

Mexico: Informational declaration of foreign investments (SAT).

Colombia: Declaration of foreign assets (DIAN).

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

The practical conclusion

Don't assume your US account is "invisible." Even though the US doesn't participate in CRS, multiple exchange mechanisms exist. Regulatory trends point toward more transparency, not less.

Declare everything you're required to. It's easier, cheaper, and far less stressful than assuming nobody will find out. The cost of non-declaration (penalties, interest, investigations) far exceeds the cost of proper compliance. Relax: at Exentax this is what we do every week, we close it before the letter ever lands in your inbox.

A properly managed LLC has nothing to hide. Your tax savings come from legal optimization. deductions, pass-through structure, efficient organization, not from hiding accounts.

Traceability is your best protection. If your tax authority ever asks about your LLC, having everything documented. invoices, distributions, Form 5472, Operating Agreement, Mercury statements, is what protects you.

The financial infrastructure supports you. Mercury ($0 wires, clear statements), Wise (transparent conversion records), Wallester (card-level expense tracking), all create documentation that proves your legitimate operation.

We're not looking for clients who want to hide money. We're looking for professionals who want to pay the right amount, operate professionally, and sleep well knowing everything is in order.

FBAR: your reporting obligation

If your combined US financial accounts (Mercury + Relay + any others) exceed $10,000 at any point during the calendar year, you must file the FBAR (FinCEN Form 114). This is YOUR filing obligation, separate from what the bank reports.

At Exentax, we file the FBAR as part of our annual maintenance service.

The trend toward global transparency

The global direction is unmistakable: more information exchange, not less. Consider:

CRS now covers 100+ jurisdictions: and more countries join each year
FATCA expanded: more countries signing bilateral IGAs
EU DAC7/DAC8: platform reporting for digital economy
OECD CAEAA: expanding crypto asset reporting globally
Beneficial ownership registries: BOI Report in the US, similar initiatives in the EU

Within 5-10 years, most financial account information will be exchanged automatically between most jurisdictions. Structure your LLC and manage your finances accordingly.

What this means for your strategy

Transparency is your friend. A well-documented LLC with proper compliance is bulletproof under any reporting regime
Don't structure around information gaps. Today's gap is tomorrow's exchange mechanism
Proper deductions save more than hiding income. Legitimate expense deductions through your LLC save you far more than any reporting gap could
Professional documentation protects you. Mercury statements, Wallester card records, Stripe reports. all create the paper trail that proves your legitimate operation

The LLC advantage isn't secrecy. it's efficiency. You pay less because your structure is more efficient, not because nobody knows about it.

One adjacent read worth having open alongside this one: Optimal tax structure for international freelancers: the complete framework, which sharpens exactly the edges we skimmed above.

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). This is where Exentax steps in: we file the form, archive the receipt and, if the authority asks, your answer is already on the desk.
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:

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 question of US-bank reporting as a perimeter exercise rather than a yes-or-no answer

The question of whether US bank accounts report to your home tax authority reads more usefully when it's treated as a perimeter exercise rather than a yes-or-no answer. The reporting depends on which bank, which type of account, which beneficial owner residency and which year — and each of these dimensions narrows or widens the perimeter independently.

Reading the question without that perimeter in mind tends to produce conclusions that are either too reassuring (assuming nothing is reported) or too alarming (assuming everything is). A perimeter view replaces both extremes with a small map that survives the first real filing.

How to anchor the perimeter analysis in the actual operating profile

The perimeter analysis anchors more usefully in the actual operating profile when each dimension is filled in with the concrete value of the case: the specific bank, the specific account type, the specific residency and the specific year. With those four values fixed, the question stops being a general debate and becomes a concrete answer.

How to capture the perimeter result in the LLC documentation

The perimeter result captures more durably in the LLC documentation as a short, dated note that lists the four values and the conclusion they yield. This note becomes the reference whenever any of the four values shifts in a later year, so the perimeter doesn't need to be re-evaluated from scratch.

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.

We set it up without you losing a weekend

Thousands of freelancers and entrepreneurs already operate their US LLC fully legally and properly documented. At Exentax we handle the entire process: formation, banking, payment gateways, bookkeeping, IRS filings and compliance in your country of residence. Book a free consultation and we will tell you honestly whether the LLC makes sense for your case, with no absolute promises.

What US accounts of your LLC report and do not report

The real discretion of US accounts is not a myth nor an absolute promise: it is a documented asymmetry of the international financial system, with concrete limits and a usage manual if you want to leverage it properly. These are the facts, no theories.

The US does not participate in CRS. It is the only G20 country that did not sign the Common Reporting Standard. Practical consequence: Mercury, Relay, Choice Financial, Evolve and Column N.A. have no duty to send balances automatically to the holder's residency country. Not a trick, the system's architecture since 2014.
Reverse FATCA is partial. The Spain Model 1 IGA (in force since 2013) requires the US to send AEAT info on accounts held by Spanish residents in US banks, but real scope is: directly-held accounts of resident individuals, with interest-generating deposits. Entity accounts (LLC) at banks like Mercury do not fall in this automatic flow with the same intensity.
What AEAT can request. Via MAP of the US-Spain treaty, AEAT can request specific information on a concrete account when there is a reasonable lead. The process takes 12-24 months, requires motivation and is used for material amounts. Not automatic, not massive.
The error that breaks the asymmetry. Receiving transfers from your US LLC account directly to your personal Spanish account leaves an origin trace visible to your Spanish bank, which does report to AEAT. The US account discretion is preserved when flow enters via Wise multi-currency with consistent motivation (member draw, salary, dividend per classification), not as gross transfer without context.

What we are asked the most

So, can I avoid declaring my US account? No: you have your own declarative duty (Modelo 720 if combined balance >50,000 €). CRS asymmetry does not exempt; what it does is remove the automatic cross that exposes omissions in CRS jurisdictions. Your duty to declare stays intact.

How long will this asymmetry last? No signal of US signing CRS short-term (5 years). There are signals of progressive reverse-FATCA intensification. The structure still works today and likely the whole decade, but you should still declare correctly so as not to depend on its permanence.

At Exentax we design the Mercury + Wise operating with coherent flows, clean Modelo 720 reporting and documentation ready for any future request, leveraging the asymmetry without turning it into a declarative omission.

How to read the question of US bank accounts and reporting to Spanish tax authorities as a stable jurisdictional mapping rather than as a worry

The question of US bank accounts and reporting to Spanish tax authorities reads more usefully when it's treated as a stable jurisdictional mapping between the country of the account, the country of residence of the beneficial owner and the framework that applies between them, than as a recurring worry.

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

References: sources on structures and jurisdictions

The comparisons and quantitative data on the jurisdictions cited here rely on official sources updated to today:

United States. Delaware General Corporation Law and Limited Liability Company Act, Wyoming Limited Liability Company Act (Title 17, Chapter 29), IRS Form 5472 instructions and IRC §7701 (entity classification).
Andorra. Llei 95/2010 de l'Impost sobre Societats (10% IS), Llei 5/2014 del IRPF and the active/passive residency framework of the Govern d'Andorra.
Estonia. Estonian Income Tax Act (deferred-distribution corporate tax at 20/22%) and official documentation of the e-Residency programme.
Spain. Ley 27/2014 (IS), Ley 35/2006 (IRPF, arts. 8-9 on residency and art. 100 on CFC) and the inbound-expat regime (art. 93 LIRPF, "Beckham Law").
OECD. Pillar Two (GloBE) and OECD Model Tax Convention with Commentaries.

Choosing a jurisdiction always depends on the holder's actual tax residency and on the economic substance of the activity; review your specific case before taking any structural decision.

_More on this topic: LLC in the United States: complete guide for non-residents._

Practical reminder

Each tax situation depends on your specific residency, the activity carried out and the contracts in force. The information here is general and does not replace personalised advice; check your particular case before taking structural decisions.

regulatory flow: from a US bank to the IRS and on to Spain's AEAT via FATCA IGA Model 1

This section busts the "US banks report nothing" myth and lays out the real data flow between the United States and Spain under the FATCA Intergovernmental Agreement Model 1 signed on 14 May 2013, in force since 9 December 2013 and refined by the subsequent administrative cooperation memoranda.

Textual diagram of the flow

US bank or EMI (Mercury, Choice, Column N.A., Wise US Inc., Relay Bank, Slash) → IRS: every financial institution classified as a reciprocal Foreign Financial Institution reports annually to the IRS the year-end balances and income of accounts whose holder is a Spanish person or entity subject to FATCA. If the account belongs to your LLC, the report uses the entity's GIIN and the beneficial owner's TIN declared on the W-9 or W-8BEN/W-8BEN-E.
IRS → AEAT: the IRS packages the calendar year data and ships it to AEAT between September and October of the following year in the FATCA XML 2.0 schema in force since July 2024.
AEAT → internal matching: AEAT cross-checks those records against your filings (Modelo 100 income tax, Modelo 720 foreign assets, Modelo 721 crypto). Divergences enter that year's "Plan Anual de Control Tributario".

What is and is not transmitted

Transmitted (FATCA XML fields): account holder or LLC name, address, Spanish TIN or NIF, account number, 31 December balance, gross interest paid during the year, dividends and other gross income, gross proceeds from financial asset sales, and the institution GIIN.

Not transmitted automatically: daily transactions, indirect beneficiaries below 25 % control, the counterparty of each operation, or the internal classification of the underlying economic activity. Also excluded are accounts below USD 50,000 held by US natural persons without US indicia under FATCA due diligence, although more recently the standard practice at Mercury and Wise US Inc. is to report all accounts tied to a Spanish TIN above zero.

Critical deadlines

31 March: FFIs must transmit the annual FATCA report to the IRS.
30 September: usual IRS-AEAT exchange window for the last closed period.
October to December: data shows up in AEAT's Renta Web and triggers any information requests.

How to prepare without surprises

Keep your W-8BEN-E aligned with the real structure, invoice and collect always from the LLC account, store monthly PDF statements, and if a 720 information notice arrives you will have five business days to respond. Run your case through the Exentax tax calculator to see the net cost of filing clean versus staying in a grey zone.

To see how this data crosses with Modelo 720 filing, continue with the step-by-step guide to Modelo 720 and 721, and if you want a full setup audit, book a call with the Exentax team and we review it with you.

### What FATCA actually transmits: technical reality vs. myth

The FATCA reporting obligation arises under IRC §§1471–1474 and Treasury Regulations §1.1471-1 to §1.1474-7 (TD 9610 of 17/01/2013), implemented worldwide via Intergovernmental Agreements. For UK FFIs, the UK-US IGA of 12/09/2012 (Model 1) routes the data through HMRC annually under regulations 2014/1506. The transmitted data set is exactly defined: account holder identification, balance at year-end, gross interest, dividends, gross proceeds. It does not include transaction-level history — that information remains accessible only via specific exchange-of-information requests under Article 27 of the bilateral tax treaty.

A practical closing note

The honest answer to "do US bank accounts get reported?" depends

less on geography and more on the actual banking partner, the

account type and the way the LLC is structured. Once those three

variables are clarified with a knowledgeable advisor, the

question loses most of its emotional weight: the member knows

exactly what is reported, to whom, and on which schedule. From

that point onward, the file becomes a simple, well-documented

yearly routine rather than a recurring source of doubt.

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