Does the arrival of CRS 2.0 mean that becoming a regular stock US securities firm requires tax reporting? Why would I say that what this friend said is wrong. I introduced the stock model of @ binancezh earlier to lay the groundwork for this tweet, as it is a more complex and troublesome explanation. Therefore, I have placed the conclusion at the beginning. Binance will not be required to file taxes through CRS due to the presence of securities firms or cooperation with securities firms. The most confusing part here is that many people confuse the concepts of "securities firms", "US stocks", "CRS", "CARF", and "tax reporting" together. Firstly, CRS is not tax reporting. CRS exchanges financial account information, not tax declaration forms. The most crucial factors here are three: Firstly, who is the financial institution responsible for maintaining this financial account. Secondly, in which jurisdiction is this financial institution located. Thirdly, whether this jurisdiction has a CRS automatic exchange relationship with the tax resident country. For example, opening an account with financial institutions participating in CRS in jurisdictions such as Singapore, Hong Kong, Switzerland, Dubai, etc., whether buying US stocks, Hong Kong stocks, funds, bonds, or cash products, as long as the account belongs to a reportable financial account under CRS and is a tax resident outside the jurisdiction where the institution is located, it may trigger CRS information exchange. The reason for being reported at this time is not 'buying US stocks', but' holding reportable financial accounts in reporting financial institutions in CRS participating jurisdictions'. On the other hand, if the underlying is American securities firms, the United States itself does not follow the CRS system for global automatic information exchange. The more common issue for non US tax residents buying US stocks is US dividend withholding tax, not CRS. Returning to Binance's stock model this time. Binance front-end provides entry and account experience, while Nest Trading, as a broker dealer under the ADGM framework, undertakes securities brokerage and order arrangement, and then routes orders to Alpaca, which completes US stock execution, clearing, settlement, and custody. The most important point here is that although Nest Trading is a financial company registered with ADGM and a broker dealer entity under the Binance ADGM framework, it is not allowed to hold or control customer funds or customer investments. This means that Nest Trading is more like a securities broker and order arrangement entity, rather than an underlying securities asset custodian. The real execution, clearing, settlement, and custody of US stocks are completed at the Alpaca level. So from the perspective of CRS, we cannot directly conclude that "Binance stock accounts must be taxed through CRS" just because Binance has Nest Trading as a brokerage entity. Here is the most important step, when dealing with CRS and CARF (as there is currently no involvement in China, it will not be discussed for now), it is necessary to first distinguish between the fully disclosed, Omnibus, and OmniSub structures. If it is fully disclosed, it does not involve CRS. Users open securities accounts one by one in the Alpaca system, and their customer information is submitted to Alpaca. Alpaca is responsible for the core processes of securities accounts, such as accounts, trading, custody, clearing, and statements. In Full Disclosure mode, the introducing broker introduces clients to Alpaca to establish personal accounts, and Alpaca receives information from each client. In this case, the US stock account is mainly not CRS, so fully disclosed can be understood as users buying and selling US stocks ETF、 The options section is mainly handled by Alpaca according to the rules of American securities firms, and the cryptocurrency exchange is only the front-end entrance. If it is Omnibus or OmniSub, it may indeed involve CRS. (But not related to Binance) In Omnibus mode, the partner manages the client's accounting and a main trading account, and does not disclose information such as the end client's name and address to Alpaca. OmniSub is a sub account technology layer on the Omnibus account, with the main account holding pooled assets of all end users. Alpaca has partial trading, holding, and cash visibility for sub accounts, but disclosure to end customers and account responsibilities are still different from Fully Disclosed. If Binance adopts the Omnibus or OmniSub mode, then Alpaca sees more Omnibus accounts at the partner level, and the sub accounts, positions, KYC, and tax residency information of end users are mainly maintained by Nest Trading. Therefore, it is indeed possible that CRS may be involved. However, Nest Trading Limited is not allowed to hold or control Client Money or Client Investments in terms of compliance. So Binance cannot choose the Omnibus or OmniSub approach, which conflicts with the license plate. Therefore, based on current information, even if Binance connects with securities firms and provides users with stock trading, Binance's customers will not be involved in CRS exchange. Of course, the maximum probability will involve CARF, and it will be more complicated. But since China is not in the country of CARF agreement, we will not discuss it for the time being. But we need to know that Hong Kong implements CARF, and will Hong Kong hand over the information of CARF to Chinese Mainland, you guess?