FATCA: Head’s Up 3301 Registered Singapore FIs

April 17, 2018

Singapore released its FATCA reporting nil paper form yesterday.


The Inland Revenue Authority of Singapore (IRAS) requires nil reporting under FATCA. IRAS does not provide an online service or separate portal for manual input and reporting of FATCA data.  Nil reporting can be accomplished through a paper form rather than through a complex electronic reporting process.


3301 Singapore Financial Institutions (FIs) have received Global Intermediary Identification Numbers (GIINs) from the U.S. Internal Revenue Service (U.S. IRS).  Each of these FIs must review their account holders and determine if they must report any Specified U.S. Persons.


US Reportable Accounts and Nil Reporting


Under the IRAS FATCA Regulations, a Reporting FI is required to submit an annual return to IRAS setting out the obligatory information in relation to (1) every U.S. Reportable Account and (2) all payments made to each nonparticipating financial institution (NPFI).


Additionally Singapore FIs that did not maintain any U.S. Reportable Accounts and did not make payment to any NPFI are required to provide a nil return.


Singapore Uses IRS IDES Portal


If a Singapore FI has reportable accounts, it must file its electronic FATCA reports through the IRS International Data Exchange Service (IDES).  However, if the Singapore FI is only required to file a nil return, it may do so either by (1) preparing a FATCA reporting packet and transmitting it through IDES, or (2) by completing a paper FATCA Nil Return and mailing it to IRAS.


Potential Cost Savings


The paper filing option provides a Singapore FI an efficient lower cost way to complete its nil reporting.  It is possible to avoid the complex reporting process of preparing FATCA reporting data in XML format, enrolling with the IRS IDES system, and transmitting the packet to IDES.


The FATCA Return Filing for the Reporting Year 2017 commenced on April 16, 2017 and the deadline for filing is May 31, 2018.


Follow this link to the IRAS site:  https://bit.ly/2HHsBFR Scroll to the bottom of the IRAS page for the link to the nil form.


Don’t Forget to De-Register


If a Singapore sub-fund currently has its own GIIN, IRAS requires that the sub-fund FATCA registration be cancelled once the umbrella fund has been issued its FATCA GIIN.  [See my previous blogs: November 24, 2017: CRS & FATCA: Singapore Sub-Fund Deregistration & Service Provider Limitations http://bit.ly/2A81Bvi and February 13, 2018: CRS: Singapore’s Updated Portal & Reportable Jurisdictions https://bit.ly/2H8BqY4].


For additional blog posts, please go to my website: elizabethmcmorrowlaw.com/blog-index.
 

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