Singapore Issues Draft Regulations and Interpretive Guidance under FATCA IGA

The Singapore Ministry of Finance, the Monetary Authority of Singapore and the Inland Revenue Authority of Singapore proposed regulations to implement the terms of an Intergovernmental Agreement ("IGA") with the United States with respect to FATCA.Singapore has agreed in substance to the terms of a Model 1 form of IGA with the United States, but the parties have not yet signed the Agreement or released a copy of the terms of such Agreement. Singapore announced that the IGA would be signed in the fourth quarter of 2014.

The draft regulations set out due diligence and reporting obligations with which Singapore financial institutions must comply in order to satisfy FATCA. In addition, the Inland Revenue Authority of Singapore ("IRAS") released a draft e-Tax Guide on FATCA that provides detailed explanations of these obligations. The draft regulations and e-Tax Guide include information on the types of financial institutions that must report account information to the IRAS; the account holders and financial accounts that are subject to reporting; exempt financial institutions, account holders and financial accounts; due diligence procedures that must be followed to identify reportable accounts; and the necessary information to be reported and the timelines for such reporting. Singapore has requested comments from the public on the draft regulations and e-Tax Guide by October 17, 2014.