Singapore Updated FATCA TIN Reporting FAQ

On February 23, 2022, the Inland Revenue Authority of Singapore (IRAS) updated its IRAS FAQs on the Foreign Account Tax Compliance Act (FATCA). Specifically, IRAS updated FAQ B.7 dealing with reporting tax identification numbers (TINs).

The FAQ is:

"How should a Reporting SGFI report TINs of Foreign Entity Account Holders (where Entity Account Holder is not a U.S. Person such as in the case of a Passive NFFE)? We have confirmed that the Entity Account Holder Type is either FATCA101 (Owner-Documented FFI with specific U.S. Owner) or FATCA102 (Passive NFFE with U.S. Controlling Persons)."

And the IRAS response:

"If account holder type is FATCA101 or FATCA102, the Account Holder/ Organisation/ TIN element can have a “TIN issuedBy” value that is a non-US issued TIN. The acceptable TIN value can consist of alphanumeric and unprohibited symbols. A non-US issued TIN does not apply for other Account Holder Types.

The ORG_TIN data element may be omitted completely or by indicating a space (e.g. <sfa:TIN issuedBy="SG"> </sfa:TIN>). However, a “TIN not populated” record-level error will be issued to the Reporting SGFI by the U.S. IRS.

To avoid receiving a record-level error from the U.S. IRS where the Entity Account Holder is not a U.S. Person, SGFI should populate the ORG_TIN data element with the foreign TIN (with the “TIN Issued by” element populated with the issuing country code) for the foreign Entity Account Holder. If there is no foreign TIN available for the foreign Entity Account Holder, Reporting SGFI may include your country code in the “TIN Issued by” element and the characters “NA” (to indicated “Not Available”) in the ORG_TIN data element (e.g. <sfa:TIN issuedBy="SG">NA</sfa:TIN>)."

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.

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