The endgame behind global transparency laws: CARF, CRS and the wealth tax agenda

In March 2025 the United States government walked back the Corporate Transparency Act. After court challenges in 2024, the Treasury announced on 2 March 2025 that it would not enforce the law against US citizens, domestic companies or their owners, and FinCEN followed with an interim rule that exempted them. A final rule, in force since 14 August 2026, made that permanent: beneficial ownership reporting now applies only to foreign entities registered to do business in the US, and FinCEN is deleting what it already held on US persons. While the headlines barely noticed, anyone tracking international tax and financial surveillance saw it for what it was: a rare and telling retreat.

Because the CTA, like its global cousins, was never only about stopping terrorists or drug cartels. It was about knowing what you own. And knowing what you own is the first step towards taxing what you own. The US blinked. Globally, the machinery is still accelerating.

The OECD's Common Reporting Standard keeps growing, and 77 jurisdictions have now committed to its newer sibling, the Crypto-Asset Reporting Framework (CARF). At the same time, a serious academic case for a coordinated tax on the largest fortunes has reached the G20. To understand where this leads, and what you can still lawfully do, you need to follow the arc that connects transparency, international agreements and the redistribution of private capital through taxation.

The real purpose behind "transparency"

Governments rarely spell out every use they have in mind for a database. The CTA was sold as an anti-terrorism and anti-money-laundering measure, requiring millions of small businesses to file beneficial ownership reports. Critics soon noticed the mismatch: the duty fell mainly on single-member LLCs and family companies, not on the networks it was meant to catch.

The system asked for detailed personal disclosures, including identity document numbers and residential addresses, and backed them with civil and criminal penalties. Its critics argued that the real product was a centralised register for future use. Under legal pressure and resistance from small business groups and the states, it has now been cut back to a fraction of its original scope.

That rollback does not mean the global agenda is dead. While the US steps back on company registers, the EU, the OECD and dozens of aligned jurisdictions keep integrating their systems.

CRS and the global data net

The Common Reporting Standard, adopted by the OECD in 2014 with first exchanges in 2017, requires financial institutions to collect tax identification numbers and report account balances and income of foreign clients. Those reports are sent to the account holder's country of residence automatically; our CRS explainer sets out the mechanics, and the amended CRS rules in Singapore show how the reports are getting more detailed.

Most people underestimate the scale. According to the OECD's Global Forum, 116 jurisdictions were exchanging under the CRS by the end of 2025, and the 2024 exchanges alone covered about 171 million accounts holding almost 13 trillion euros. Real estate you own directly is not a financial asset under the CRS, but that gap is closing too: in December 2025, 26 jurisdictions pledged to join a new OECD framework for exchanging information on offshore real estate, with first exchanges expected in 2029.

The public story is always about tax evasion. The technical function is broader: data centralisation. And when you centralise information about assets held across borders, you build the infrastructure that a tax on those assets would need.

Gabriel Zucman and the wealth tax blueprint

For years, wealth taxes were seen as politically toxic and technically unworkable. That changed when the French economist Gabriel Zucman began publishing detailed, data-driven proposals.

In June 2024, in a report commissioned by Brazil's G20 presidency, he proposed a coordinated minimum tax on the very richest: 2% of wealth a year for people worth more than a billion dollars, as a top-up for those whose income tax falls short of it. The report names the Common Reporting Standard as the starting point for enforcing it, and asks for real estate and crypto to be brought into the exchange of information as well. The G20 finance ministers who met in Rio in July 2024 did not adopt the 2% rule; they agreed to "seek to engage cooperatively" to ensure that ultra-high-net-worth individuals are effectively taxed.

In other words, the transparency tools of the last decade may not have been the end goal. They may turn out to be the plumbing. Once the data exists, identifying, valuing and taxing what people own becomes a policy choice rather than a technical problem.

The debate is no longer theoretical. In France, the National Assembly voted on a "Zucman tax" and rejected it on 31 October 2025, by 228 votes to 172; the 2026 budget law enacted no general wealth tax. In Brussels, Commissioner Wopke Hoekstra confirmed in a written answer to a Member of the European Parliament in May 2025 that the Commission had launched a study on wealth-related taxes in December 2024, while stressing that taxation remains a national competence. The proposals keep failing. They also keep coming back.

What CARF is and why it matters

As if CRS were not enough, the OECD has added a second regime aimed at crypto and digital assets. Crypto was once the escape hatch.

Under CARF, crypto-asset service providers, exchanges, brokers and some wallet providers among them, collect the tax residence and tax number of their customers and report their transactions every year. Exchanges of crypto for money or for other crypto-assets, and transfers, are reported without a threshold; the only de minimis line is USD 50,000 for retail payments a provider processes for a merchant. Self-hosted wallets do not report anything themselves, but the platform reports, in aggregate, what you transfer to wallets it does not know to belong to another provider.

According to the OECD Global Forum's list of September 2026, 77 jurisdictions have committed: 46 with first exchanges in 2027, 27 in 2028, including Switzerland, Singapore, Hong Kong and the UAE, and four in 2029, including the United States. Platforms in the UK and the EU have been collecting the data since 1 January 2026. Within a few years, your crypto on a platform will be about as visible as your bank account.

From surveillance to taxation: the playbook

Once these systems are running, what stops governments from using them for wealth taxes, retroactive assessments or asset freezes? Law and politics, and not much else. Information has always come before taxation. Every register that tells the state what you own makes the next tax on it easier to design and to collect.

The current climate, with deficits, ageing populations and growing welfare obligations, makes that more likely, not less. The easiest political move is to target the wealthy, defined ever more broadly, with a narrative of fairness and redistribution. That is the trajectory unless individuals take control of their own structures.

How to protect yourself, lawfully

None of this is a call for evasion. It is a call for lawful, early planning, while the options are still wide.

1. Choose your tax residence deliberately. A country with no wealth tax, no exit tax and a sensible treatment of foreign income changes more than any account ever will. The UAE, Panama, Paraguay and some Caribbean states are often on the list; what matters is that the residence is real.

2. Use proper structures for proper purposes. Trusts, foundations and insurance wrappers can protect assets against creditors and succession disputes when they are set up lawfully and declared. They are not a way around CRS or CARF: both look through entities to the people behind them.

3. Diversify where you bank. The United States does not take part in the CRS and exchanges information under FATCA instead; a US account for non-residents therefore follows different rules from a European one. Our overview of countries outside the CRS covers the rest. Different does not mean invisible, and the income stays taxable at home.

4. Know what your crypto platform reports. Self-custody keeps your keys in your hands; it does not make the withdrawal from a platform disappear from its report.

5. Hold some assets that are not account balances. Physical gold, land or a business you run are reported differently from a portfolio at a bank, and they spread your risk across more than one system.

6. Consider a second citizenship. A second passport gives you options if your home country ever ties taxation or exit rules to citizenship.

7. Act while every option is still open. Opening and holding accounts abroad is legal, your income remains taxable where you are resident, and we never help anyone hide anything. What planning buys you is choice, and choice shrinks every time a new register goes live.

The illusion of consent

All of this is done in the name of fairness, transparency and the fight against inequality. But once governments know everything you own, they have the means to decide how much you keep, and there will always be a moral justification for taking more.

There is no opt-out once you are inside the system. Your protection lies in structuring your residence, your banking and your assets in ways that remain legal, declared and resilient. The US has backed down on company registers, for now. The OECD has global ambitions, and the proposals for taxing wealth have not gone away.