Singaporean CPF & FBAR
Singaporean CPF & FBAR: As far as the IRS is concerned, the Singaporean CPF (Central Provident Fund) is reportable on the FBAR. The CPF is considered a type of Foreign Bank and Financial Account, which is reported on FinCEN Form 114. Since there is no tax treaty between the US and Singapore, the CPF is generally taxable as well. In other words, while it is tax deferred in Singapore, there is no tax treaty between the U.S. and Singapore — and this further complicates the analysis. From a tax perspective, there is the issue of the contributions to the fund; growth within the fund, and distributions out of the fund. While different tax professionals may take contrasting approaches to the U.S. taxation of Singapore CPF, the Internal Revenue Service has issue memoranda in the past on the tax treatment of a CPF, which generally determined the income is taxable (growth and non-distributions inclusive).
While we have a much more detailed analysis on the U.S. Taxation of CPF, but let’s focus on FBAR:
FBAR Reporting for CPF
Even though the CPF is comprised of three (3) different parts, the entire CPF’s maximum account value is generally reported together on the FBAR each year that the person’s annual aggregate total of all their foreign accounts combined exceeds $10,000.
CPF Amnesty for Missed Prior Reporting
The Internal Revenue Service’s FBAR Amnesty Programs are programs developed by the Internal Revenue Service to assist Taxpayers who are already out of compliance for non-reporting.
Some of the more common programs, include:
- Voluntary Disclosure Program (VDP or “New” OVDP)
- Streamlined Domestic Offshore Procedures
- Streamlined Foreign Offshore Procedures
- Delinquency Procedures
- Reasonable Cause
Can I Just Start Filing FBAR This Year Instead?
No, unless the current year is the first-year you had an FBAR Reporting requirement.
If you had a prior year reporting requirement, but only begin to start filing in the current year (Filing Forward) it is illegal. In the world of offshore disclosure, this is referred to as an FBAR Quiet Disclosure.
The IRS has warned taxpayers that if they get caught in a FBAR Quiet Disclosure situation, it may lead to willful penalties and even a criminal investigation by the IRS Special Agents.
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