Does the USA report my US bank account to Nigeria under CRS?

No. The USA does not participate in CRS. The USA uses its own system called FATCA (Foreign Account Tax Compliance Act). Under FATCA, US financial institutions report accounts held by US persons (US citizens, green card holders, and US tax residents) to the IRS - not to foreign tax authorities. A Nigerian with a US bank account who is not a US person is not automatically reported to FIRS under FATCA.

What is FATCA and how does it differ from CRS?

FATCA is a US law that requires foreign financial institutions to report accounts held by US persons to the IRS. CRS is an OECD framework where countries report accounts held by foreign tax residents to each other. The key difference: FATCA focuses on US persons globally, while CRS focuses on foreign account holders in participating countries. The USA reports outward (US persons abroad) but does not receive inward reports from other countries under CRS.

Does my US LLC get reported to Nigeria?

A US LLC owned by a Nigerian who is not a US person is not automatically reported to FIRS under FATCA. However, if the LLC has a US bank account and you receive distributions from it, those distributions may be subject to US withholding tax. The LLC itself is a pass-through entity for US tax purposes - the tax obligation flows to the owner. Consult a US tax adviser and a Nigerian tax adviser about your specific obligations.

FATCA for Nigerians with US Bank Accounts 2026: What Gets Reported and to Whom

Key facts (2026)
USA: does NOT participate in CRS
USA uses: FATCA (Foreign Account Tax Compliance Act)
FATCA reports: US persons' accounts to IRS (not to foreign tax authorities)
Nigerian with US account (non-US person): not automatically reported to FIRS under FATCA
Primary source: IRS (irs.gov/fatca)

Tax adviser required
FATCA and US tax law are complex. This post explains the framework. It is not tax advice. Consult a qualified US tax adviser and a Nigerian tax adviser before making any decisions about US accounts or US business structures.

The USA is the most significant exception to the CRS automatic exchange system. While over 100 countries automatically share financial account information with each other, the USA does not participate in CRS. Instead, it uses FATCA - a system that works very differently.

What FATCA is

FATCA (Foreign Account Tax Compliance Act) is a US law enacted in 2010. It requires:

Foreign financial institutions (banks, brokers, etc. outside the USA) to report accounts held by US persons to the IRS
US financial institutions to report accounts held by foreign persons to the IRS (for withholding purposes)

The key difference from CRS: FATCA is about US persons globally. CRS is about foreign account holders in participating countries. The USA reports outward (US persons abroad) but does not receive inward reports from other countries under CRS.

Primary source: https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca

What this means for Nigerians with US accounts

Scenario 1 - Nigerian with a US bank account (not a US person)

If you are a Nigerian national who is not a US citizen, green card holder, or US tax resident, and you have a US bank account:

Your account is not automatically reported to FIRS under FATCA
Your account may be subject to US withholding tax on certain types of income (interest, dividends)
You may need to complete a W-8BEN form for your US bank confirming you are not a US person

Scenario 2 - Nigerian with a US LLC

A US LLC owned by a non-US person:

Is not automatically reported to FIRS under FATCA
Is a pass-through entity for US tax purposes - profits flow to the owner
May be subject to US withholding tax on certain distributions
The owner may have US tax filing obligations depending on the LLC's activities

Scenario 3 - Nigerian who is also a US person (dual citizen, green card holder)

If you are a Nigerian who is also a US citizen or green card holder:

You are a US person for tax purposes
Your worldwide income is subject to US tax
Your foreign accounts (including Nigerian accounts) must be reported to the IRS under FBAR (FinCEN 114) and FATCA Form 8938
This is a complex situation requiring a US tax adviser

The W-8BEN form

When you open a US bank account or investment account as a non-US person, you will be asked to complete a W-8BEN form. This form:

Certifies that you are not a US person
Claims any applicable tax treaty benefits
Determines the withholding tax rate on your US-source income

Completing this form correctly is important. Providing false information is a criminal offence.

FBAR - the other US reporting requirement

If you are a US person (US citizen, green card holder, or US tax resident) with foreign bank accounts exceeding USD 10,000 in aggregate at any point during the year, you must file an FBAR (FinCEN 114) with the US Treasury.

This is separate from FATCA and applies to US persons with Nigerian, UAE, or any other foreign bank accounts.

The Nigeria-USA tax treaty

Nigeria and the USA do not have a double taxation treaty. This means:

If you are both a Nigerian tax resident and a US person, you may face double taxation
There is no treaty mechanism to offset Nigerian tax against US tax or vice versa
This is a complex situation requiring advisers in both jurisdictions

Evidence note

FATCA framework sourced from the IRS at https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca, retrieved October 2026. This post is general information only - not tax advice. Consult qualified tax advisers in both Nigeria and the USA before making any decisions.