Offshore Account Reporting by Residency Status (FBAR / CRS / FATCA)
Foreign account reporting residency drives it: US persons file FBAR and FATCA, CRS-country residents are auto-reported, non-doms and non-residents differ.
Your offshore-account reporting obligations are set by your tax residency, not your nationality or where the account sits. A US person must self-report foreign accounts on the FBAR and FATCA forms; a resident of a CRS country has their foreign balances reported about them automatically by banks; a non-dom may face reporting only on amounts brought home; and a non-resident is generally reported in whichever country actually holds tax residency over them. Same account, four very different outcomes.
There are two fundamentally different machines at work, and people constantly confuse them. FBAR and FATCA's Form 8938 are US self-reporting regimes: you tell the government about your accounts. The Common Reporting Standard (CRS) is the opposite, your bank tells your country of residence about you. The same residency line that decides whether you owe income tax also decides which of these machines points at you, and that is exactly the line this guide and the Tax Days day-counter help you find.
Two systems: self-reporting vs. automatic exchange
Before mapping it to status, separate the two regimes, because they behave in opposite directions:
- US self-reporting (FBAR + FATCA). If you are a US person, you file. The FBAR (FinCEN Form 114) goes to Treasury; FATCA's Form 8938 goes to the IRS with your return. The obligation is on the taxpayer to disclose.
- CRS automatic exchange (the rest of the world). More than 100 jurisdictions exchange account data under the OECD's Common Reporting Standard. Your bank identifies which country you are tax-resident in and reports your balances and income to that country's tax authority, no form from you required.
- FATCA's other half (the bank side). FATCA also makes foreign banks report US-person account holders to the IRS. So a US person living abroad is reported both ways: they self-file the FBAR/8938, and their foreign bank reports them too.
The United States runs FATCA but is not a CRS participant. That asymmetry is why your declared tax residency on a bank's self-certification form matters so much: it routes your data into either the US system, a CRS country, or both.
How reporting changes with each residency status
Here is the same set of foreign accounts seen through four common statuses. Notice that the trigger is always which jurisdiction you are tax-resident in, decided by the same day-counts and domicile tests you track everywhere else on this site.
| Your status | Who reports | What is captured |
|---|---|---|
| US person (citizen, green-card holder, or SPT resident) | You self-file FBAR + Form 8938; your foreign banks also report you under FATCA | Worldwide foreign financial accounts and specified foreign assets above the thresholds |
| Resident of a CRS country | Your banks abroad automatically report your accounts to your country of residence | Account balances, interest, dividends, and sale proceeds in any other CRS jurisdiction |
| Non-dom / remittance-basis resident | Often the same CRS data flows, but home taxation may attach only to remitted funds | Accounts are still reported; tax may apply only to amounts brought into the country |
| Non-resident (of a given country) | That country generally does not receive reports about your other-country accounts | You are reported to wherever you are resident, not to the one you left |
US persons: you file, and your bank files about you
If you are a US person, a citizen, a green-card holder from the first day of lawful permanent resident presence, or someone who crosses the weighted 183-day Substantial Presence Test, you inherit two self-reporting duties at once. The FBAR captures foreign financial accounts whose aggregate value crosses a relatively low threshold at any point in the year. Form 8938 reaches a broader set of specified foreign assets at higher thresholds that vary by filing status and whether you live inside or outside the US.
Because the US is not in CRS, the reciprocal flow runs through FATCA instead: foreign banks identify their US-person account holders and report them to the IRS directly. The practical consequence is that a US person abroad cannot quietly rely on a foreign account going unseen, the account is reported by the bank even in years the taxpayer forgets to file. The disclosure clock starts on your residency starting date, so the year you become a US person is the year both duties switch on.
Becoming a US person is a single act that turns on income tax, the FBAR, and Form 8938 simultaneously. If you are counting days toward the SPT, you are also counting down to your first foreign-account filings, decide whether to restructure accounts before residency attaches, not after.
CRS-country residents: the bank reports you
If you are tax-resident in one of the 100-plus CRS jurisdictions and hold accounts in another CRS country, you typically file no special foreign-account form at all. Instead, when you opened the account, the bank asked you to self-certify your country of tax residence and tax identification number. Each year it reports your balance, interest, dividends, and gross proceeds to your home tax authority through the automatic exchange network.
This is why the residency self-certification you sign at account opening is not a formality. If your day-counts push you into a new country's residency mid-year, the kind of crossover the 183-day calculator is built to flag, your bank may need an updated self-certification, and your reported residence can change. Declaring a residence you cannot support is exactly the mismatch that surfaces in an audit, because the CRS data and your filed returns are cross-checked.
- You usually don't file a separate form, reporting is the bank's job under CRS.
- Your self-certified residence drives the routing, get it wrong and your data flows to the wrong (or an extra) country.
- A change in residency means a change in who's told, moving tax homes mid-year can split a year's reporting between two authorities.
- Non-reporting is not non-detection, even if you never declare the account, your resident country likely already received it.
Non-doms and the remittance basis: reported, but taxed differently
A non-dom (or any remittance-basis taxpayer) is a special case where reporting and taxation diverge. In remittance-basis regimes, historically the UK, and ongoing variants in Ireland, Cyprus, and Malta, a resident is taxed on foreign income and gains only to the extent they are brought into the country. But being on the remittance basis does not make your offshore accounts invisible. If you are tax-resident in a CRS country, the bank still reports your foreign accounts to that country; the remittance basis only changes whether and how those amounts are taxed.
That gap matters. A non-dom can be perfectly correct that little or no tax is due on un-remitted foreign income, while their home authority simultaneously holds CRS data showing the full offshore balance. The two are reconciled by the claim you make on your return, which is why clean records of what was remitted versus what stayed offshore are the heart of defending a non-dom position. So assume your offshore accounts are already reported to your country of residence under CRS, and build your records around proving what you remitted rather than around the hope the accounts stay unseen. The UK has also been reshaping its non-dom rules toward a residence-based regime, so confirm the current treatment before relying on the old remittance model.
Non-residents: reported where you actually live
If you are a non-resident of a particular country, that country generally does not receive CRS reports about accounts you hold elsewhere, you are reported to wherever you are tax-resident. The risk for genuine movers is the opposite of hiding: it is being reported to a country you thought you'd left. Banks act on the last residency self-certification on file, so a stale declaration can keep routing your data to a former home long after you've moved.
This is acute for people whose residency is genuinely ambiguous, perpetual travelers, yacht crew and pilots, and anyone between homes. A bank requires some declared tax residence, and the absence of a clear one tends to default to whatever address or prior certification it has. The perpetual-traveler myth runs aground here: 'resident nowhere' is not a box on a CRS form. Establishing a defensible residence, and keeping the bank's certification aligned with it, is what keeps your reporting clean.
- You're reported to your actual residence, determined by treaty tie-breaker rules when two countries both claim you.
- Stale self-certifications mis-route data, update the bank when you genuinely change tax homes.
- US citizens are never CRS-only, citizenship keeps you a US person and inside FBAR/FATCA no matter where you reside.
- Ambiguous residence is a reporting problem, not a loophole, banks resolve it against you, not in your favor.
Pin down the residency line that controls reporting
Every branch above turns on a single fact: which jurisdiction holds tax residency over you, and from what date. That is decided by day-counts, domicile, and treaty tie-breakers, the same mechanics behind the 183-day rule and the Substantial Presence Test. Tax Days logs your presence trip by trip and shows the exact day you cross into (or out of) residency in each jurisdiction, so the self-certification you sign at a bank matches the reality you can defend on a return.
If your situation is genuinely mixed, citizen of one country, resident of another, accounts in a third, start by mapping each account to the residency that controls it, then to the regime (FBAR/FATCA self-reporting, CRS automatic exchange, or both) that applies. Get the residency line right and the reporting obligations fall out of it almost mechanically. Not sure which framework is yours? See which guide applies to your situation.
Frequently asked questions
Does my offshore account reporting depend on citizenship or residency?
Primarily residency, with one big exception: US citizens are US persons for FBAR and FATCA no matter where they live. For everyone else, it is your tax residency that decides which country's authority receives reports about your accounts, mostly through the automatic CRS exchange.
What is the difference between FBAR, FATCA, and CRS?
FBAR and FATCA's Form 8938 are US self-reporting forms you file about your own foreign accounts. CRS is automatic exchange: your foreign bank reports your accounts to your country of tax residence. FATCA also makes foreign banks report US-person account holders to the IRS, so US persons are covered both ways.
Do non-doms have to report foreign bank accounts?
If you are tax-resident in a CRS country, your foreign accounts are reported to that country by your bank regardless of non-dom status. The remittance basis changes how those amounts are taxed (often only when brought home), not whether the accounts are reported. Keep records of what you remit.
If I'm a non-resident, will my old country still see my accounts?
Generally only if your bank still has an old residency self-certification on file pointing there. CRS routes your data to your current tax residence, so the practical step when you move is to update the bank's certification so it reports you to the right country.
Is the US part of the CRS?
No. The United States runs its own regime, FATCA, instead of joining the Common Reporting Standard. US persons therefore self-file the FBAR and Form 8938, and foreign banks separately report US account holders to the IRS under FATCA.
How do I know which reporting regime applies to me?
Find your tax residency first. If you are a US person, you are in FBAR and FATCA. If you are resident in a CRS country, your banks report you automatically. Track your days and residency starting date with a tool like the calculator at /tools/183-day-calculator, then map each account to the controlling residence.
Sources & further reading
Every rule on this page is drawn from primary sources. Verify the current law before making a residency decision.