What does your Israeli bank actually report about you, and to whom?
Your Israeli bank reports your account to a tax authority abroad every year, and which authority depends entirely on your citizenship. If you hold US citizenship or a green card, you are reported under FATCA and your data reaches the IRS. If you are a British, Canadian, South African, French, or Australian oleh with no US tie, you are reported under the OECD Common Reporting Standard (CRS)and your data reaches your home country's tax office. The question is never whether you are reported, only to whom.
This blindsides almost every oleh, because a lifelong Israeli with one passport is reported nowhere: there is no foreign authority to send their data to. The moment you arrive carrying a second citizenship, your brand-new חשבון עובר ושב (Cheshbon Over VaShav) (current account) becomes a reportable foreign account in the eyes of a tax system on the other side of the world. Understanding which of the two regimes catches you is the whole game.
Not advice
Why are there two systems instead of one?
Because the United States went first and alone. FATCA, enacted in the US in 2010, forced foreign banks worldwide to identify and report their US-person account holders to the IRS; Israel and the US signed an intergovernmental agreement to implement it.3 The rest of the world then built a multilateral version of the same idea, the OECD Common Reporting Standard, so that countries could swap account data with each other automatically.1 The catch: the US never joined CRS. It already had FATCA and saw no reason to participate in a second system, so to this day the US exchanges data on a one-way FATCA basis rather than as a CRS member.
For an oleh, the practical consequence is clean and slightly counterintuitive: US persons are reported through FATCA and are explicitly outside CRS, while everyone else is reported through CRS and outside FATCA. You are in exactly one lane. The form you sign at the teller, the טופס (Tofes)(form), is the bank's way of sorting you into the correct lane.
FATCA vs CRS at a glance
The two regimes do the same job, automatic annual reporting of your account to a foreign tax authority, but they catch different people, route data to different places, and use different paperwork. The table maps the differences that matter to an oleh.
| FATCA | CRS | |
|---|---|---|
| Who it catches | US citizens and green-card holders (US persons) | Tax residents of any participating country except the US |
| Where your data goes | To the IRS, via the Israel Tax Authority | To your home country's tax authority, via the Israel Tax Authority |
| Participating jurisdictions | US plus the banks of partner countries (a hub-and-spoke US system) | Roughly 100+ jurisdictions exchanging multilaterally |
| Form you sign | IRS Form W-9 (FATCA self-certification) | CRS self-certification (country of tax residence) |
| Is the US in it? | It is the entire point of it | No, the US never joined |
| Native Israeli with one passport | Not reported | Not reported |
What information actually leaves Israel under each regime?
Roughly the same data set under both: who you are and what the account is worth. The bank reports identifying details and account-level figures, typically your name, your foreign taxpayer number (for US persons, the מספר זהות (Mispar Zehut) does not satisfy this; they need your US TIN), the account number, the year-end balance, and income such as interest credited during the year.4 It is account information, not your transaction history; the receiving authority sees the snapshot, not every העברה (Haavara) (transfer) you made.
Under FATCA this package goes to the Israel Tax Authority and is forwarded to the IRS once a year.2 Under CRS the same kind of package goes to the Israel Tax Authority and is exchanged with the tax authority of the country you declared as your residence on the self-certification.1 In both cases the bank is the reporter and the Israel Tax Authority is the conduit; you are not mailing anything to a foreign government yourself.
FATCA reporting is not the same as your own FBAR/8938
Worked example: a dual US/UK citizen opens an Israeli account
Take Daniel, who holds both US and UK passports and makes aliyah. He opens an Israeli current account and the teller hands him a self-certification form. Here is how the two regimes sort him, side by side:
- FATCA (US side): Daniel is a US person, full stop. He signs IRS Form W-9, gives the bank his US TIN, and the account is reported to the IRS via the Israel Tax Authority every year, exactly as it would be for a US-only citizen.2
- CRS (UK side): Here is the twist. Daniel might assume his UK citizenship puts him in CRS too. It does not put him there because he is American, US persons sit outside CRS by design. His UK passport only matters for CRS to the extent he is still a UK tax resident; once he is UK-non-resident, his CRS country of residence is Israel, and HMRC is not a reporting destination at all.
The upshot a native Israeli never has to think about: holding a second citizenship does not shield you from US reporting and does not split your account between two foreign authorities. As long as US person status applies, FATCA controls and the IRS is the destination. The home-country lane (CRS) only re-engages if you are still tax-resident there. Compare that to a UK-only oleh in the same branch, who signs a CRS form, names Israel (or the UK, until non-residence) as their residence, and never sees a W-9.
Which form will the bank put in front of you?
The bank decides by asking one question first: are you a US person? If yes, you get the W-9 and the FATCA track; if no, you get the CRS self-certification.2 A few practical notes that catch olim:
- You sign the form for the bank, not the IRS or HMRC. The W-9 and the CRS self-certification both stay with the bank as the basis for its reporting; you never mail either to a tax authority.4
- Declining to disclose is the actual risk. Refusing to certify your status or your tax residence is what creates a problem, banks can restrict or decline the account. The reporting itself is routine and applies identically to every foreign-tied customer.
- Update the bank when your residence changes. CRS turns on tax residence, which shifts as you become non-resident of your home country after aliyah. If your certified residence is out of date, the data can be exchanged with the wrong authority.
- A second citizenship does not move a US person out of FATCA. If you are American, the W-9 is coming regardless of what other passports you hold.
One boundary for US olim specifically: this article is about information reporting on a bank account, which authority sees that the account exists. It is not about how anything you hold is taxed. In particular, the punitive US PFIC regime on non-US pooled investments is a separate topic with its own dedicated material; no pooled investment vehicle is named, recommended, or compared on this page, so PFIC is out of scope here. If you plan to invest from your Israeli account, read the PFIC material before you buy anything, because the right move for a US person is the opposite of the standard Israeli-resident advice.
Knowledge Check
You are a dual US/Canadian citizen who has just made aliyah. Under which regime does your new Israeli bank account get reported?
Every oleh with an Israeli bank account is reported to a tax authority abroad, and the only question is which one. If you are a US person (a US citizen or green-card holder), your account is reported under FATCA and reaches the IRS via the Israel Tax Authority, because the United States never joined the OECD Common Reporting Standard and runs its own FATCA system instead. Everyone else, including UK, Canadian, South African, French, and Australian olim, is reported under CRS, which exchanges account data with your country of tax residence across roughly 100+ jurisdictions. You sit in exactly one lane: US persons sign IRS Form W-9 and are outside CRS, while everyone else signs a CRS self-certification naming their country of tax residence. A dual US/other citizen is still controlled by FATCA, so a second citizenship does not move a US person out of US reporting. Both regimes report information only (who you are and what the account is worth), not transaction history, and neither one is a tax. FATCA bank reporting also never replaces a US person's own FBAR (FinCEN Form 114) or Form 8938 filings.
Generally no, you sit in one lane. If you are a US person, FATCA applies and you are outside CRS, because the US is not a CRS participant. If you are not a US person, CRS applies and FATCA does not. The only way both can be live is a dual citizen who is a US person and also still tax-resident in another CRS country at the same time, and even then the US side flows through FATCA, not CRS.
No. FATCA is a US system for US persons. With a UK passport and no US citizenship or green card, you sign a CRS self-certification rather than a W-9, and your account is exchanged under CRS with your country of tax residence, never sent to the IRS. The IRS only enters the picture if you separately hold US person status.
Yes, if you are a US person and your accounts cross the threshold. FATCA is what the bank reports about you, while the FBAR (FinCEN Form 114) is a separate filing you owe once your non-US accounts together exceed $10,000 at any point in the year, and Form 8938 is another separate disclosure on your US return. Bank reporting never substitutes for your own filings.
No. Both are information-reporting regimes, not taxes. They tell a foreign authority that the account exists and what it is worth, while whether anything is taxable is a separate question answered by that country's tax rules and any treaty. The report itself imposes no tax.
Your CRS country of residence becomes Israel, so there is no longer a foreign authority to exchange your account with under CRS. That is why keeping your self-certification current matters: a stale form can route your data to a country you have already left. Becoming non-resident is governed by each country's own rules, such as the UK Statutory Residence Test, Canadian residential-ties tests, and South African ordinary-residence rules, not by aliyah alone.
Roughly the same data set under both regimes: who you are and what the account is worth. The bank reports identifying details and account-level figures, typically your name, your foreign taxpayer number (for US persons, your US TIN), the account number, the year-end balance, and income such as interest credited during the year. It is account information, not your transaction history, so the receiving authority sees the snapshot rather than every transfer you made.
The bank decides by asking one question first: are you a US person? If yes, you get IRS Form W-9 and the FATCA track. If no, you get the CRS self-certification, on which you name your country of tax residence. You sign the form for the bank, not for the IRS or HMRC, and it stays with the bank as the basis for its reporting. Declining to certify your status or residence is the real risk, because banks can restrict or decline the account, and a US person cannot avoid the W-9 by holding a second passport.
Next: what you actually sign at the teller
