When a bank asks a tax question, it is already a systems problem
Mara is a founder with a simple goal: stay mobile without breaking the operating rhythm of her company. She is not chasing loopholes. She wants predictability. She wants a residency position that is truthful and defensible, banking relationships that do not freeze at the wrong time, and an asset setup that will not unravel when a new compliance officer takes over.
Her move looked clean on paper. She had a residence card in one place, a tax residency certificate in another, and assets held through a tidy stack of entities. She assumed the hard part was done.
Then came the “normal” banking refresh.
The bank did not start with tax rates. It started with:
- confirm tax residence for CRS self-certification
- confirm controlling person details for entities
- provide proof of address that matches what is on file elsewhere
- document source of wealth and source of funds
- explain why spending patterns, dependents’ presence, and business activity looked anchored in a different jurisdiction than the residency narrative implied
None of these requests felt dramatic. They felt procedural. That is the point.
The OECD’s Common Reporting Standard (CRS) is built around financial institutions collecting information and jurisdictions automatically exchanging that information annually. In parallel, CRS due diligence frameworks place real weight on obtaining valid self-certifications and using them to determine tax residence for reporting purposes. Your residency story is no longer only a tax return story. It is also a bank file story.
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Add FATCA for US-linked clients and structures, where foreign financial institutions may report information about accounts held by US taxpayers or face withholding consequences. The compliance stack is not optional. It is the operating system.
This is why the new unit of analysis is not residency alone. It is the residency banking–asset triangle.
If any side of the triangle contradicts the others, you do not just risk an audit. You risk friction: delayed transfers, enhanced due diligence, account restrictions, or relationship exits. And those outcomes tend to arrive when you are trying to close a deal, relocate, or move capital fast.
MARKET & CAPITAL REALITY CHECK
Why the triangle tightened, and what compliance actually optimizes
1) CRS strengthened the “tax residence inside onboarding” logic.
CRS is explicitly designed so jurisdictions obtain information from financial institutions and exchange it automatically. As a result, banks need a repeatable method to determine the account holder’s tax residence, and CRS FAQs describe obtaining self-certifications as part of due diligence for new accounts. The practical effect is simple: your bank must be able to explain your tax residence position as documented, even if your life is complicated.
2) FATCA creates a separate, high-scrutiny lane for US persons.
The IRS explains that FATCA generally requires foreign financial institutions and certain non-financial foreign entities to report on foreign assets held by US account holders or face withholding on certain payments. The US Treasury similarly describes FATCA as requiring FFIs to report information about accounts held by US taxpayers (or certain foreign entities with substantial US ownership).This matters because US-linked clients can trigger additional onboarding depth, periodic recertifications, and additional reporting expectations.
3) AML standards pull the asset side of the triangle into view.
The FATF Recommendations set the global framework for AML measures. FATF guidance emphasizes adequate, accurate, and up-to-date beneficial ownership information for trusts and similar legal arrangements and mechanisms to verify it.So the “asset map” is not only a structuring preference. It is part of how a bank evaluates risk, control, and transparency.
4) Enforcement pressure rewards documentation quality.
One reason private wealth onboarding has become more document-heavy is that regulators punish weak controls. As a concrete example of how “source of wealth” verification failures appear in enforcement actions, the UK FCA’s Barclays final notice includes discussion of source-of-wealth guidance and the absence of adequate follow-up when documentation was thin.Even if your situation is entirely legitimate, you still need a file that reads as coherent.
The Tier 2/3 reality: Smaller banking hubs and offshore centers often run stricter onboarding than clients expect, because they live inside correspondent networks and reputation risk. The question is not “Is this legal?” The question is “Is this easy to explain to our auditors, regulators, and counterparties?”
THE PLAYBOOK
How to align the triangle without pretending your life is simple
Who this playbook is for:
- Founders and executives with multi-country movement
- Families with multiple homes and school calendars
- Allocators with multi-bank custody and cross-border entities
- Advisors building defendable, scalable client stacks
Conditions that need to be true:
- You are willing to prioritize consistency over convenience
- Your residency position is grounded in lived reality and evidence
- You will treat the bank file as a core asset, not paperwork
The Triangle Framework
Residency: Where are you tax resident and why, using the rules and evidence that apply?
Banking: What does your KYC file say, and does it match the residency story?
Assets: Who owns what, where, and who controls decisions?
Three example triangles
Archetype A: US high earner with global assets
- Residency: US citizen or resident alien status may mean worldwide income remains taxable regardless of where they live, subject to specific rules and relief provisions.
- Banking: FATCA-linked onboarding and periodic recertifications are common.
- Assets: Entity and trust structures must be mapped to beneficial ownership and control expectations.
Archetype B: UK or EU resident shifting to a lower-tax base
- Residency: The tie factors and evidence trail must support the new center of life.
- Banking: CRS self-certification and proof-of-address consistency become key.
- Assets: Custody location and entity control must not contradict the residency story.
Archetype C: Founder with operating company in one country, management in another
- Residency: Personal story must reflect where life is actually organized.
- Banking: The bank will ask where decisions are made and who controls the entities.
- Assets: Board minutes, signatories, and org charts matter because they show governance reality.
The document set that reduces friction
A “Triangle File” is not about volume. It is about clarity.
Residency pack (personal):
- primary home evidence, long-term accommodation documents
- family footprint summary where relevant
- travel log supporting, not substituting, the story
- any official residency documentation, where applicable
Bank pack (KYC ready):
- consistent proof of address across accounts
- tax residence self-certifications kept up to date (and aligned)
- source of wealth and source of funds narrative with supporting documentation
Asset pack (structure clarity):
- entity org chart with ownership percentages
- beneficial ownership and controlling person analysis
- governance evidence: board minutes, resolutions, signatory lists
- list of banks, custodians, and jurisdictions with a one-line rationale
Steps (action-oriented)
- Write the one-page story. Where you live, where you work, where decisions happen, where assets sit.
- Run a contradiction check. If your card spend, school calendar, and medical footprint say Country A, do not let your bank file say Country B.
- Standardize identities and addresses. Inconsistent addresses are a frequent trigger for “enhanced due diligence” cycles.
- Build a source-of-wealth file you can reuse. If a regulator can later ask a bank “show me why you believed this,” your goal is a file that answers that question cleanly.
- Review annually or after major life changes. New baby, new home, new directorship, new jurisdiction, new bank. Any of these can change the triangle.
Risks & frictions (do not skip):
- A bank can treat contradictions as risk, even when a tax authority has not questioned you
- CRS and FATCA documentation expectations can multiply across institutions
- Complex structures without transparent beneficial ownership mapping increase onboarding time and raise closure risk
DEAL & PRODUCT LENS
Where the products sit in the stack
The “triangle” created a market for services that look like admin but function like capital infrastructure.
- Banking readiness reviews that produce a reusable KYC pack and consistent narrative
- Residency evidence frameworks designed to survive scrutiny, not social media
- Governance and structure documentation for cross-border entities, including beneficial ownership mapping and decision-making records
Ticket sizes depend on complexity, number of jurisdictions, and number of institutions. The real return is reduced friction: fewer blocked transfers, faster onboarding, and lower disruption risk during liquidity events.
ACCESS & NEXT MOVES
How to plug into this ecosystem responsibly
Types of actors to speak to first:
- Cross-border tax counsel with dispute experience
- Private banking onboarding or compliance specialist
- Corporate governance professional for entity control and documentation
Recommended sequence:
- Validate residency posture and evidence.
- Build the KYC narrative and address consistency.
- Map assets and governance.
- Only then add new institutions, new structures, or new jurisdictions.
“A bank does not need to accuse you to slow you down. A contradiction is enough.”
Key datapoints box:
- CRS is designed for jurisdictions to obtain account information from financial institutions and exchange it automatically on an annual basis.
- CRS due diligence guidance describes obtaining self-certifications to determine tax residence for reporting purposes.
- FATCA generally requires foreign financial institutions to report certain information about US account holders or face withholding consequences.
SOURCES & DISCLOSURE
Key sources used: OECD CRS consolidated text (2025), OECD CRS FAQs (Dec 2025), IRS FATCA overview, US Treasury FATCA summary, FATF Recommendations and beneficial ownership guidance, FCA Barclays final notice (2025).
Standard I-Invest disclosure: This article is for informational purposes only and does not constitute investment, legal, tax, or migration advice. Markets, regulations, and outcomes vary by jurisdiction and individual circumstances. Readers should seek independent professional advice before making decisions.