If you work in Singapore for a US-listed company like Google, Meta, Microsoft, Amazon, Apple, NVIDIA, Salesforce or Adobe, a large part of your pay probably comes as RSUs (restricted stock units).
Over a few vesting cycles, these grants can become the largest part of your net worth. And most people leave them sitting in their employer's stock, or move them into US-listed ETFs. That creates three risks:
- Estate tax risk: US shares above $60,000 can attract US estate tax of up to 40% for non-residents. Singapore has no estate duty, but that does not stop the US taxing US assets.
- Concentration risk: As a rule of thumb, once more than 20% of your net worth sits in one company, your salary and your savings depend on the same share price.
- Access risk: Vested shares usually sit at a US broker such as Fidelity, Morgan Stanley or E*TRADE. If you pass away, that account is frozen until the US estate tax is settled, which can take 18 to 24 months.
All three can be fixed. This guide explains how Singaporeans can de-risk RSUs, avoid the estate tax trap, and diversify into UCITS ETFs through Paasa.
Table of contents
- A quick note on RSUs
- The estate tax trap most Singaporeans miss
- De-risk RSUs with UCITS
- RSUs vs US ETFs vs UCITS
- How Singapore taxes RSUs, US ETFs and UCITS
- How Paasa helps you de-risk RSUs
A quick note on RSUs
RSUs are share grants your employer gives as part of your pay. Instead of receiving the shares on day one, you get them over a vesting schedule, for example 25% a year over four years.
Once an RSU vests, it becomes actual shares in a brokerage account, usually with Fidelity, Morgan Stanley, E*TRADE or Schwab. You can then hold the shares or sell them.
For employees at companies like Google, Meta or Microsoft, these holdings can grow into a portfolio worth several hundred thousand dollars. That is when the real question starts: how to protect it from a single-stock crash, from US estate tax, and from a frozen account your family cannot reach.
The estate tax trap most Singaporeans miss
Most RSU holders watch their employer's share price. Far fewer plan for US estate tax.
| How it works | Non-residents holding more than $60,000 in US-situs assets, including RSU shares and US-listed ETFs, are subject to US estate tax at death. |
|---|---|
| Tax rate | Progressive, up to 40%. |
| Who it hits | Even if you live in Singapore and have never filed a US tax return, your family would face this tax before inheriting your US shares. |
| Singapore relief | None. Singapore has no estate duty and no estate tax treaty with the US. |
The tax is worked out in two steps. The US rate schedule is applied to the full value of your US-situs assets to get a tentative tax, and a flat unified credit of $13,000 is subtracted. That is why $60,000 is the threshold: at that size the credit exactly cancels the tax.
Here is how much is at stake:
| RSU portfolio value | Estate tax payable | Share of holdings lost |
|---|---|---|
| $250,000 | $57,800 | 23% |
| $500,000 | $142,800 | 29% |
| $1,000,000 | $332,800 | 33% |
For the full breakdown, see US estate tax for Singaporeans, or estimate your own exposure with the US estate tax calculator.
De-risk RSUs with UCITS
UCITS (Undertakings for Collective Investment in Transferable Securities) are funds regulated under EU rules and domiciled in markets like Ireland and Luxembourg. They follow strict rules on diversification, risk management and investor protection.
For Singaporeans with RSU wealth, UCITS ETFs offer four advantages:
- Estate tax protection: Because UCITS ETFs are domiciled outside the US, they are not US-situs assets. Moving RSU proceeds into them removes the US estate tax exposure, while keeping your exposure to US companies.
- Diversification: A single UCITS ETF can hold hundreds of companies. An S&P 500 UCITS ETF gives you the same US market exposure as its US-listed equivalent, and there are UCITS funds for global equities, Europe, emerging markets, bonds and themes.
- Half the dividend tax: Singapore residents pay 30% US withholding on dividends from US shares and US-listed ETFs. Ireland-domiciled UCITS ETFs pay 15% inside the fund, and Singapore does not tax the rest. See US dividend withholding tax for Singapore investors.
- Income or reinvestment, your choice: For Singapore residents, accumulating and distributing UCITS share classes carry the same tax, so you can pick based on whether you want cash income or automatic reinvestment.
For a full explainer, see UCITS ETFs for Singapore investors.
RSUs vs US ETFs vs UCITS
Here is how the three options compare for RSU wealth.
| RSUs (employer stock) | US-listed ETFs | UCITS ETFs (Ireland/Luxembourg) | |
|---|---|---|---|
| US estate tax | Up to 40% once US-situs holdings exceed $60,000 | Up to 40% once US-situs holdings exceed $60,000 | No US estate tax exposure |
| Diversification | None, tied to one company | Broader, but mostly US | Global: US, Europe, emerging markets, bonds, themes |
| Volatility | Very high, tied to your employer (job and wealth risk) | Lower than a single stock, still US-centric | Spread across markets and sectors |
| Dividends | 30% US withholding, if the stock pays one | 30% US withholding | 15% US withholding inside the fund |
| Account access at death | Frozen until US estate tax is cleared | Frozen until US estate tax is cleared | No US estate tax clearance needed |
| Overall | Builds wealth, but concentrated and exposed to estate tax | Better spread, still exposed to estate tax | Estate tax shield, lower dividend tax, global reach |
How Singapore taxes RSUs, US ETFs and UCITS
For Singapore residents, the main tax event on RSUs happens at vesting. After that, moving the shares into UCITS ETFs is generally tax-free.
| RSUs (employer stock) | US-listed ETFs | UCITS ETFs (Ireland/Luxembourg) | |
|---|---|---|---|
| When taxed in Singapore | At vesting, as employment income | Not taxed in Singapore | Not taxed in Singapore |
| Singapore tax rate | Your progressive income tax rate on the value at vesting | Nil on dividends and gains | Nil on dividends and gains |
| Tax on sale | Generally none in Singapore or the US | Generally none in Singapore or the US | None in Singapore |
| Tax on dividends | 30% US withholding, final | 30% US withholding, final | 15% inside the fund |
| US estate tax | Yes, above $60,000 | Yes, above $60,000 | None |
- At vesting: The value of the shares when they vest is taxed as employment income, and your employer reports it to IRAS (usually in Appendix 8B).
- On sale: Singapore does not tax capital gains, unless IRAS treats you as trading shares as a business (IRAS). The US generally does not tax non-residents on gains from selling US shares (IRS Publication 515).
- On dividends: Singapore does not tax foreign dividends received by individuals, so the only tax is the US withholding.
Example. Suppose you are a Singapore resident holding Google shares from RSUs that vested at $250,000 and are now worth $400,000. You sell them all and buy an S&P 500 UCITS ETF.
| Item | Amount |
|---|---|
| Sale proceeds | $400,000 |
| Gain since vesting | $150,000 |
| Singapore tax on the gain | $0 |
| US tax on the gain | $0 |
| Amount reinvested in UCITS ETFs | $400,000 |
The result: the switch costs only brokerage and currency conversion, and removes a potential $108,800 US estate tax bill
The $108,800 is the estate tax on $400,000 of US shares (tentative tax of $121,800 less the $13,000 credit).
Note: The vesting value was already taxed as employment income. Selling after vesting does not create a second Singapore tax bill.
How Paasa helps you de-risk RSUs
Paasa makes the move from concentrated RSUs to a diversified UCITS portfolio straightforward.
- Transfer your shares via ACATS: Your vested shares at Fidelity, Morgan Stanley, E*TRADE or Schwab move into your Paasa account through the Automated Customer Account Transfer Service (ACATS), the standard process used by US brokerages.
- Sell at your own pace: Once the shares are in your account, sell some or all of them, depending on your goals. This cuts your exposure to a single company.
- Reinvest into UCITS ETFs: Put the proceeds into UCITS ETFs or Paasa's managed strategies for global diversification, estate tax protection and lower dividend tax.
Typical timeline: Most transfers complete in 3 to 5 business days.
To talk it through with the team, schedule a call or write to support@paasa.com.
About Paasa
Paasa is a global investing platform giving investors access to markets across the US, UK, Europe and Asia.
- RSU transfers made simple: Move vested shares from your employer's broker into your Paasa account via ACATS, then diversify from there.
- Estate tax-free US exposure: Hold Ireland- and Luxembourg-domiciled UCITS ETFs that track US indices without holding US-situs assets, in USD, GBP or EUR.
- An account in your own name: Your holdings are held with Interactive Brokers as custodian, and you get read-only access to IBKR alongside the Paasa dashboard.
