CRS and FATCA — will a foreign broker report your account?

A foreign brokerage account can be reportable even when the broker is outside your country. The answer depends on the institution, the account, your tax residence and the reporting rules that apply. CRS and FATCA concern information exchange; they do not calculate your tax or replace your own filing obligations. This article explains the international process and separates it from the explicitly labelled Polish example.

What CRS does — and which countries matter

CRS, the Common Reporting Standard, is the OECD standard for automatic exchange of financial-account information. Reporting institutions identify relevant accounts under local implementing law. Information normally moves first to their domestic tax authority and then to a partner authority under an effective exchange relationship. Start with the OECD consolidated CRS standard; participation, reporting and the destination of an individual account are separate questions.

A country appearing on a CRS list does not prove that every account there is reported to every other country. Check the actual institution and account classification, residence information and effective exchange relationship for the relevant period. The OECD explanation of exchange agreements shows why the relationship between the two jurisdictions matters. In the European Union, DAC2 implements an account-information exchange framework; it is an EU rule, not a worldwide tax return.

What can be reported — and why closure still matters

Reportable information can include the account holder's identifying details, tax residence and taxpayer identification number, the institution and account identifier, balance or value, and specified payment totals. The fields depend on the account type and applicable rules. Gross proceeds and credited amounts are not automatically your taxable profit. A CRS report is not a substitute for a transaction ledger or the tax calculation required in your country.

Keep records for the whole applicable period, including an account you closed. Under the stated DAC2/CRS assumptions in the diagram, actual closure during the year is included in reporting rather than treated as proof that the account never existed. That does not determine the amount of income, a capital loss or a tax bill. The DAC2 account-reporting provisions are the source for this EU example.

Reporting and exchange run on their applicable annual timetable. A broker's reporting deadline, the authorities' exchange date and your personal filing deadline are different dates. Identify each from the relevant jurisdiction's rules rather than treating a Polish filing date or a September exchange schedule as the deadline for every reader. Do not postpone a required return while waiting for information exchange.

FATCA — assess the US connection separately

FATCA is a United States regime. It includes reporting by certain foreign institutions about relevant US accounts and separate obligations for specified US taxpayers. The IRS FATCA overview distinguishes the institution-side system from the taxpayer's duties. US citizenship or other US tax status can matter even when a person lives elsewhere.

Using a US broker, a US payment route or a dollar-denominated account does not itself make someone a US person. Assess the actual status and applicable rules. A person with connections to more than one country should check CRS residence information and FATCA status separately instead of choosing whichever regime appears simpler.

For the separate Poland–US agreement, Article 2 also specifies information the United States supplies on Polish reportable accounts, including qualifying deposit interest and US-source dividends or other income. That reciprocal scope is not identical to CRS or to Poland’s US-account reporting fields. Absence of US-person status therefore does not establish absence of every exchange channel.

A broker's report does not automatically discharge a taxpayer's own asset-reporting duties. The IRS information for individuals explains that certain US taxpayers must report specified foreign financial assets themselves, generally on Form 8938. Whether a particular person must file depends on the rules and thresholds; other reporting regimes may also require separate checks.

What information exchange cannot tell you

The absence of an automatic report does not establish a tax exemption. Reporting coverage and income-tax treatment have different legal tests. Equally, receiving a report does not prove that every amount shown is taxable. Work from your residence, the exact transaction and the local income classification. Our tax-residence article introduces that assessment with country-specific examples.

This separation also prevents a common reconciliation mistake. An account statement can contain deposits, withdrawals, proceeds and a trading result. Do not compare every one of those amounts directly with a single taxable-income figure. Keep a record explaining which entries your local calculation uses and why.

Five times the gross proceeds, the same result

Assume two reportable custodial securities accounts subject to the applicable gross-proceeds reporting rule. Each starts with PLN 20,000 and ends with cash only. A buys securities for PLN 19,500 and sells them for PLN 20,000 once. B makes five successive purchases for PLN 19,900 each and sales for PLN 20,000 each. All events are hypothetical, within one year, without credit, commission or other flows.

A has PLN 20,000 gross sale proceeds, PLN 19,500 purchase costs and PLN 500 result. B has PLN 100,000 gross proceeds, PLN 99,500 purchase costs and the same PLN 500 result. Both end with PLN 20,500 cash. The fivefold proceeds difference does not establish fivefold taxable income. Identify report fields and transaction records before applying the local tax rules.

This is a securities-custody model, not an automatic field rule for every CFD. The OECD 2025 consolidated text describes gross proceeds separately from balances and other income, with exceptions and jurisdictional implementation to check. Publishing that consolidated standard does not by itself establish that every amendment already applies in every country.

Poland example — PIT-38 is not a worldwide form

Poland only: a Polish tax resident's qualifying private derivative income under Article 30b is generally calculated and filed on PIT-38. The Polish Ministry of Finance rate guidance identifies the relevant 19 percent capital-income rate. First establish the applicable income category, revenue, eligible costs, conversion rules and any permitted relief. A broker's location alone does not settle that classification.

For a Polish filing, confirm whether the contracting broker entity provides PIT-8C and reconcile all accounts. If it does not, collect the records needed to prepare the calculation yourself. Our Polish PIT-38 example for tax year 2024 is historical and country-specific. Prop-firm remuneration is a separate classification question, covered in the Poland guide to prop-firm payouts.

For readers elsewhere, start with the relevant tax authority's guidance on foreign accounts and income, then the exact instrument and taxpayer category. A Polish deadline, NBP exchange rate or PIT form is not your default. The taxes library distinguishes international context from country guides.

What to do tomorrow

1. Record your residence facts for the relevant year. Identify the countries whose domestic rules could apply and any relevant treaty. Check the country information through the OECD tax-residence resource; an address, nationality or day count alone is not a universal answer.
2. Check the institution's residence declaration. Review the tax-residence information, taxpayer identifiers and US-status questions on the account. Follow the institution's procedure to correct inaccurate information or report a relevant change. Retain the supporting documents and dated confirmation.
3. Download the records, including closed accounts. Save statements, payment records and actual closure confirmations for the applicable period. Preserve the original currency and recognition dates needed by your local calculation; an annual reporting summary may not contain every detail you need.
4. List your own filing obligations and deadlines. Separate income-tax returns from foreign-account or asset reports, and distinguish them from the institution's reporting timetable. Use the relevant official forms and tax year. Seek jurisdiction-specific help for dual residence or an uncertain contract classification.