Singapore has updated its CRS FAQs. The updated FAQs provide revised guidance on determining whether the holder of a new account is a reportable person. The FAQ directs Financial Institutions to obtain self-certification for the purposes of reporting when an account is opened if the account is to be treated as a preexisting account or if the FI determines the account holder may be a reasonable person.
According to the FAQ, if it is not possible when the account is opened then the FI may have 90 days to obtain self-certification. The FAQ makes it clear this extension is allowed only when circumstances do not permit contemporaneous self-certifications, such as when an insurance contract has been assigned from one person to another or where an investor acquires an interest in a trust on the secondary market.
About the Author
Jesse Rooney is a Regulatory Analysis Counsel at Sovos. His research focuses on AEOI, ACA, information return, and sales tax issues. Mr. Rooney received his B.A. from Framingham State University and his J.D. from the University of Massachusetts School of Law. He is licensed to practice in Massachusetts.More Content by Jesse Rooney