US Tax of Singapore CPF & IRS FBAR & FATCA Compliance

US Tax of Singapore CPF & IRS FBAR & FATCA Compliance

Singaporean CPF & US Tax Treatment

Singaporean CPF & US Tax Treatment: When it comes the IRS tax rules for U.S. Persons with Singapore CPF (Central Provident Fund), it can get very complicated. CPF is a foreign pension. While it is tax deferred in Singapore, there is no tax treaty between the U.S. and Singapore, which further complicates the analysis.  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. At that time, the IRS determined that both the contributions to the CPF and growth within the fund are taxable in the year the contribution was made and/or the fund growth occurred. 

We have a much more detailed analysis on the U.S. Taxation of CPF, but let’s review 5 common facts to know about the CPF:

Singapore CPF has Three (3) Components to it

The CPF has been a part of Singapore for more than 60-years.

It is a compulsory form of retirement, which takes on the form of both Pension and Social Security.

In the U.S. it is treated as foreign pension, with immediate tax consequences.

The three (3) components to the CPF are:

  • Ordinary Account
  • Special Account
  • Medisave

While there are three different accounts within the CPF, technically each person only has one CPF account, so it is generally reported as one CPF on the U.S. tax return (not as three different accounts).

Contributions to Singapore CPF are Taxable in the U.S.

Deferred salary contributions into the CPF are taxable. 

Thus, even though it is very similar to the 401K, the U.S. does not provide tax deferred treatment to deferred salary contributions.

By contrast, the U.S. and U.K. tax treaty provides for such tax deferred status for employment salary contributions in certain circumstances.

Accrued CPF Growth is Taxable in the U.S.

Likewise, the growth within the CPF is taxable in the year it accrues.

It is not grossed-up and taxed at distribution (which is a common misconception).

Once the income has been taxed, it is not taxed again at distribution since the tax basis will include the previously taxed income.

FBAR Reporting of CPF

CPF is considered an account that would be reported on the FBAR.

FATCA Form 8938 Reporting of CPF

CPF is considered a foreign pension that is reportable on Form 8938.

We Specialize in IRS Offshore Disclosure & Compliance

Our firm specializes exclusively in international tax, and specifically IRS offshore disclosure

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.

Each case is led by a Board-Certified Tax Law Specialist with 20-years experience, and the entire matter (tax and legal) is handled by our team, in-house.

*Please beware of copycat tax and law firms misleading the public about their credentials and experience.

Less than 1% of Tax Attorneys Nationwide Are Certified Specialists

Our lead attorney is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.

Recent Case Highlights

  • We represented a client in an 8-figure disclosure that spanned 7 countries.
  • We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
  • We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
  • We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
  • We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.

How to Hire Experienced Offshore Counsel?

Generally, experienced attorneys in this field will have the following credentials/experience:

  • 20-years experience as a practicing attorney
  • Extensive litigation, high-stakes audit and trial experience
  • Board Certified Tax Law Specialist credential
  • Master’s of Tax Law (LL.M.)
  • Dually Licensed as an EA (Enrolled Agent) or CPA

Interested in Learning More about our Firm?

No matter where in the world you reside, our international tax team can get you IRS offshore compliant.

We specialize in FBAR and FATCA. Contact our firm today for assistance with getting compliant.

Schedule a Confidential Reduced-Fee Initial Consultation with a Board-Certified Tax Attorney Specialist


930 Roosevelt Avenue, Suite 321, Irvine, CA 92620