Are Singapore Central Depository (CDP) Accounts Required For FBAR?

Are Singapore Central Depository (CDP) Accounts Required For FBAR?

Are Singapore Central Depository (CDP) Accounts Reported FBAR?

Are Singapore Central Depository (CDP) Accounts Required For FBAR: Oftentimes, when it comes to Singapore and offshore reporting to the IRS, the main issues involve the CPF (Central Provident Fund) and Bank Accounts, such as DBS (POSB) and Citibank. But, many US Person Singaporeans also have a Central Depository Account(s), which is used to hold assets traded on the SGX (Singapore Stock Exchange). A common question that our international tax lawyers receive about CDP, is whether or not a Central Depository Account (CDP) is reportable on the FBAR, FATCA Form 8938 — and other IRS International Information Reporting Forms. Let’s review the basics of whether a Central Depository (CDP) SGX account is included for FBAR and FATCA purposes:

What is the Central Depository?

The Central Depository is actually a wholly owned subsidiary of SGX. 

As provided by the SGX:

“Central Depository Core Functions

      • The Central Depository (Pte) Limited (CDP) was established in 1987 and is a wholly owned subsidiary of SGX. CDP provides integrated clearing, settlement and depository services for a wide range of products in the Singapore Securities Market.


CDP provides clearing, settlement and custodian services for the following products traded on SGX-ST, our securities market:

      • Shares

      • Bonds/notes

      • Preference shares

      • Rights

      • Warrants/transferable subscription rights (including structured warrants)

      • Exchange traded funds (ETFs)

      • Funds

      • Unit trusts (including real estate investment trusts (REITs) and business trusts)

      • Stapled securities

      • American Depository Receipts

      • Perpetual securities

      • Singapore Government Securities (SGS)

      • Singapore Depository Shares

      • Exchange Traded Notes

*CDP also provides custodian services for unlisted corporate bonds and Singapore Savings Bonds (SSBs).”

 Types of Central Depository (CDP) Account Types

There are various different types of Depository Accounts, depending on the types of investments held in the account and/or sub-account.

As provided by the SGX

      • Accounts held in CDP are broadly classified as:

      • Direct accounts

        • Held directly by investors
      • Sub-accounts

        • Held by investors through Depository Agents (DAs). Sub-account holders maintain a direct relationship with the DAs.
      • CDP may also open omnibus accounts for Clearing Members for settlement purposes.

Why is Central Depository Accounts Reportable for FBAR & FATCA?

Since the Central Depository Accounts are foreign accounts, maintained by the US person and in a foreign country (Singapore) — then the account would be considered “Foreign” and therefore qualify as an account for Foreign Financial Account purposes for FBAR and Foreign Financial Asset purposes for FATCA.

FBAR/FATCA Amnesty Program Summary

The FBAR/FATCA 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:

Can I Just Start Reporting the Central Depository Account for this Year?

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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