Cross-border Wealth
The Assets Your Singapore Will Can't Reach
Your will governs less than you think. Foreign property, offshore accounts, and US-listed shares each follow their own rules, and one of them carries a 40 percent trap most Singapore investors have never heard of.
The Assets Your Singapore Will Can't Reach
Most people imagine a will as a single instruction that governs everything they
own. Write it, sign it, and the whole estate falls into line. For a life lived
entirely within one country, that is roughly true. The moment your wealth crosses
a border, it stops being true, and the gaps are not obvious until it is too late
to fix them.
Here is what a Singapore will actually reaches, and what it does not.
Foreign property follows the foreign country
Real estate is governed by the law of the country it sits in, not the country you
live in. A condominium in Malaysia, a flat in London, a house in Australia:
each is dealt with under that country's succession and tax rules, and each may
require its own local grant before it can pass to your heirs. Your Singapore will
may need to be re-proved abroad, or a separate local will may be needed. Without
planning, your family inherits not just the asset but a foreign legal process, in
a foreign language, at the worst possible time.
Offshore accounts follow the account, and the paperwork
An offshore account does not automatically flow through your Singapore will in
the way you assume. Access depends on the institution's own requirements, the
jurisdiction it sits in, and whatever nomination or joint arrangement is
attached to it. Families routinely discover an account exists but cannot get at
it for months, because nobody left a map and the institution answers only to its
own process.
The US trap: 40 percent above USD 60,000
This is the one that catches sophisticated Singapore investors, and it has
nothing to do with being American.
If you hold US-situated assets when you die, your estate can face US estate tax,
even though you are not a US citizen or resident. US-listed shares are the
classic exposure. That direct holding of Apple, Nvidia, or an S&P 500 tracker
domiciled in the US is a US-situs asset. So is US real estate.
The exemption for a non-resident, non-citizen is not the multi-million figure US
persons enjoy. It is USD 60,000. Above that, the excess is taxed at rates up to
40 percent, and the estate is expected to file a US return, Form 706-NA, before
the assets can be cleanly released. A Singapore investor with a large US equity
portfolio can be sitting on a substantial, invisible liability that their
Singapore will does absolutely nothing to address.
The fix is usually structural and needs to be done in advance: how the US assets
are held, and through what, rather than simply owning them in your own name.
There are well-understood ways to reduce or remove the exposure, but almost none
of them work retroactively at death.
The through-line
A will is a jurisdictional instrument. It is powerful inside its own borders and
progressively weaker outside them. Cross-border wealth needs cross-border
planning: the right instrument in each place, a clear map of what sits where, and
attention to the tax that attaches to the asset's location rather than to yours.
If any meaningful part of your wealth sits outside Singapore, or is invested
directly into US markets, the honest position is that your will is only part of
your plan, and possibly a smaller part than you think.
*If your wealth crosses borders, or you hold US-listed assets directly, the next
step is a confidential discussion to map the exposure. Please see the
Confidential Discussion Notice before
you begin.*