Singapore recently published an update to their CRS Frequently Asked Questions (FAQs). Last updated in February 2017, the July 2017 update provides clarity and additional guidance in a number of areas that concern Singaporean financial institutions reporting under the Common Reporting Standard. These updates include the following sections.
- Section B.5, Reserved Investment Power Trusts: This section was amended to provide qualifications for investment entities based on Section VIII A(6)(b) of the CRS. Previously, Reserved Investment Power Trusts were not considered investment entities under the aforementioned section.
- Section C.8, Reactivation of dormant accounts: This section was updated with guidance on “reactivating” pre-existing accounts prior to the respective due dates (12/31/17 for high value accounts, 12/31/18 for lower value and preexisting entity accounts).
- Reporting FIs will have until the review due date that is applicable to establish if the account is reportable.
- Section E.11A: This section was added with the July 2017 update, and presents two scenarios as examples of situations in which FIs may or may not be required to register with Singapore for reporting and due diligence purposes.
- Section E.23: This section was added with the July 2017 update, and relates to the discovery of indicia as they relate to categorizing accounts as undocumented and tax resident statuses.
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About the Author
Paul Ogawa is a Junior Regulatory Counsel at Sovos Compliance. As part of the Regulatory Analysis team, his main areas of focus are state and federal tax withholding, the Affordable Care Act (ACA), and Canadian tax information reporting. Prior to Sovos, Paul worked as a litigation attorney in Boston area law firms, representing clients in insurance subrogation claims, family law matters, and employment disputes. Paul is a member of the Massachusetts Bar, earned his B.A. from Brandeis University and his J.D. from the Suffolk University Law School.More Content by Paul Ogawa