Classify before reporting
Determine whether the entity is a custodial, depository, investment or specified insurance institution, a non-reporting institution, or an active/passive NFFE. FATCA focuses on specified US persons, including relevant US controlling persons of passive NFFEs. Use the applicable new/pre-existing account procedures, documentary evidence and validated self-certifications; the FATCA pre-existing-account boundary is before 1 July 2014, not the CRS 2017 date. Excluded accounts and non-reporting categories have specific conditions.
Register, submit and retain controls
Reporting SGFIs generally register with the US IRS for a GIIN and provide registration information to IRAS. Submit annual information or nil returns to IRAS by 31 May following the reporting year using prevailing XML or permitted fillable-PDF procedures. Data include holder identifiers, balances and applicable payments. Outsourcing does not remove compliance responsibility. The guide predates August 2026 legislative changes, so forthcoming trustee obligations must be read with the later amendments rather than inferred from this edition alone.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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