Singapore has long been a magnet for American professionals β tech executives at regional headquarters, finance professionals at MAS-regulated banks, and entrepreneurs building Southeast Asian operations. The city-state offers a stable legal system, zero estate duty, and a common-law framework that Americans find familiar. But estate planning in Singapore still requires deliberate action, particularly around the Central Provident Fund (CPF), which does not pass under your will.
This guide explains what Americans in Singapore need to know about local will requirements, CPF nominations, US estate tax obligations, and the steps to protect a cross-border estate.
Singapore's Wills Act (Cap. 352) governs testamentary capacity and formal requirements. A valid Singapore will must:
Singapore recognises wills made in foreign countries if they were valid where made, under Section 5 of the Wills Act. This means a validly executed US will can in principle cover Singapore assets. However, enforcing it requires a local probate process that takes additional time and expense.
The Central Provident Fund (CPF) is Singapore's mandatory social security system. Employees and employers both contribute to CPF, which covers retirement savings (Ordinary Account, Special Account, Retirement Account), housing (for HDB purchases), and healthcare (MediSave). For expats who have worked in Singapore and contributed to CPF, the balance can be substantial β sometimes hundreds of thousands of Singapore dollars.
CPF savings do not form part of your estate. They cannot be distributed under your will. They are distributed under a separate CPF Nomination, which you make directly with the CPF Board.
A CPF Nomination directs your CPF savings to named individuals in specified proportions. You can make a nomination at any CPF Service Centre or online through the CPF website. Two witnesses are required (not beneficiaries). If you do not make a nomination, your CPF savings are paid to the Public Trustee of Singapore, who then distributes them according to the Intestate Succession Act β which may not match your wishes.
Americans in Singapore should make a CPF Nomination as a high priority β separate from their will, and reviewed after every major life change.
ExpatLegalWills helps Americans in Singapore create a US-law will covering their worldwide estate. Handle the Singapore-specific items (CPF, SRS) separately, but don't neglect the global picture.
Create Your US Expat Will βThe Supplementary Retirement Scheme (SRS) is a voluntary savings programme for retirement. Unlike CPF, SRS funds do form part of your estate and can be distributed under your will. Ensure your Singapore will or US will addresses these assets.
Property held under joint tenancy in Singapore passes automatically to the surviving joint tenant upon death β it does not pass under your will. If you own Singapore property as a joint tenant, the property is not part of your estate.
Life insurance policies with named beneficiaries pass directly to those beneficiaries, not through your estate. Keep beneficiary designations on Singapore-issued policies current.
Singapore abolished estate duty in February 2008. There is no inheritance tax or estate duty on Singapore assets regardless of the size of the estate. This makes Singapore genuinely attractive for estate planning and wealth accumulation.
Despite Singapore's zero-tax approach, US citizens owe federal estate tax on their worldwide estate. Singapore assets β bank accounts, brokerage accounts, property, business interests β are all included in the taxable estate for US purposes. The 2026 exemption is approximately $13.99 million per individual.
There is no US-Singapore estate tax treaty. However, since Singapore imposes no estate tax, the practical effect is that you pay US estate tax only (if your estate exceeds the threshold), with no double taxation.
Singapore financial institutions are FATCA-compliant and report US citizen account holders to the IRS. Your Singapore bank accounts are not hidden from US tax authorities. Ensure your estate plan accounts for all Singapore financial accounts, and your executor knows where to find them.
Many Americans in Singapore hold Singapore dollar investments, ETFs, REITs, and other assets through MAS-regulated brokerages. These assets form part of your estate and can be distributed under a Singapore or US will. For significant investment portfolios, a Singapore will drafted by a local lawyer provides the most efficient probate path.
Probate in Singapore is handled by the Family Justice Courts. The executor named in the will applies for a Grant of Probate. For a well-drafted Singapore will, the process typically takes two to six months. A US will can be recognised through a resealing process, but this requires additional time and cost.
For Americans with both US and Singapore assets, the recommended approach is:
Americans in Singapore face unique complexity. ExpatLegalWills handles the US layer β start online and get your worldwide estate covered.
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