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Understanding CRS

Posted: Tue Jul 12, 2022 7:42 am
by Gulliver
I recently tried to open a new bank account in Japan and was notified I would have to fill out a CRS (Common Reporting Standard) form since I am a US citizen.

I opened a couple of accounts in Japan five or six years ago and this was not a requirement. Apparently since 2017 all Japanese banks are now required to file the form for any new accounts.

As usual with tax matters in Japan, I can find no clear guidance so I’m hoping someone here has a better understanding.

From what I could glean from the JTA website we will now be required to report US financial Holdings (Banks, brokerage accounts, insurance, pension etc.) to the Japanese bank you are applying to who will in turn submit the information to the JTA?

Information as to the extent the JTA has authority/ability to go snooping into your accounts is rather nebulous (perhaps purposely)? Is there a dollar amount the triggers it? Or is this just a way to make sure you’re paying tax on all your mutual fund accounts, interest-earning bank accounts etc.? What does this accomplish that FATCA does not?

I think I’ll just keep my old accounts so I don’t have to go through the trouble. FATCA makes sense to me as a tool to combat money laundering but CRS seems a bit invasive. Or am wrong?

Re: Understanding CRS

Posted: Tue Jul 12, 2022 8:55 am
by runmanTX

Re: Understanding CRS

Posted: Tue Jul 12, 2022 10:05 am
by captainspoke
Gulliver wrote: Tue Jul 12, 2022 7:42 am...
From what I could glean from the JTA website we will now be required to report US financial Holdings (Banks, brokerage accounts, insurance, pension etc.) to the Japanese bank you are applying to who will in turn submit the information to the JTA? ...
Barring some big change that I missed, I don't think that's correct. I've never heard of having to report US holdings to banks here, and if the NTA wanted to know that, they'd be asking directly. Large transfers (inbound) are reported the NTA, but I think that's for any nationality, not just US.

AFAIK, you need to give them your SSN, and your My Number, too.

Separately, the NTA does require a foreign asset report to be submitted to them (usually along with a tax return) if the total value of your foreign assets is over 50 million yen. But the banks have no role in that at all. (This is a little like the FBAR.)

Re: Understanding CRS

Posted: Tue Jul 12, 2022 12:06 pm
by Gulliver
runmanTX wrote: Tue Jul 12, 2022 8:55 am A quick search revealed this:

www.nta.go.jp/taxes/shiraberu/kokusai/crs/pdf/02en.pdf
Yeah that’s the one I read before. It left me more confused than when I started. :?

Re: Understanding CRS

Posted: Fri Jul 15, 2022 6:51 am
by Gulliver
Well, it was a nice surprise that I was able to answer my own question this time during the application process.

As I suspected, if your only source of income comes from Japan and the US, CRS is somewhat of a redundancy. It requests exactly the same information that you include FATCA form (tax residency and tax identification number). The difference being that now that information will also be more readily available to the other CRS compliant member countries upon request.

If you earn income from the approximately 100 CRS compliant countries, other than the US, this may be a new situation for you in that the funds and transactions in your various country’s accounts may be discoverable by CRS compliant signatories.

https://en.m.wikipedia.org/wiki/Common_ ... g_Standard

Welcome to the club.