Irish-Domiciled : 15% dividend tax
U.S.-domiciled vs Ireland-domiciled ETF estate tax comparison:
| Criteria | U.S.-Domiciled ETF | Ireland-Domiciled ETF (UCITS) |
|---|---|---|
| Estate Tax Exposure | Yes – considered U.S.-situs property; subject to U.S. estate tax. | No – Irish-domiciled, not U.S.-situs; not subject to U.S. estate tax. |
| Exemption Threshold | Only US$60,000 exemption; above this, U.S. estate tax up to 40% applies. | Not applicable; no U.S. estate tax filing required. |
| Dividend Withholding Tax | 30% on U.S. dividends for Singapore investors (non-treaty country). | 15% effective rate via U.S.–Ireland tax treaty inside the fund. |
| Singapore Context | Singapore has no estate duty – U.S. estate tax is the main risk. | Same – but Ireland domicile avoids the U.S. estate tax risk entirely. |
| Community / Expert View | Generally discouraged by global investors due to estate tax trap and higher dividend tax. | Widely recommended for non-U.S. investors (e.g. CSPX, VWRA, VUAA) to avoid U.S. estate tax. |
Quick notes (context you may find useful):
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Singapore currently has no estate duty, so the key exposure here is the U.S. estate tax if you hold U.S.-situs assets directly (including U.S.-domiciled ETFs). (IRS)
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Irish-domiciled UCITS ETFs also tend to be dividend-efficient for U.S. stocks (15% treaty rate inside the fund vs 30% if you hold U.S.-domiciled ETFs directly as a Singapore tax resident), but that’s a dividend withholding point, not estate tax. (No Money Lah)
Feature |
S&P 500 ETF (e.g., SPY, VOO) | NASDAQ ETF (e.g., QQQ, QQQM) |
|---|---|---|
| Index Tracked | S&P 500 (500 large US companies) | NASDAQ-100 (100 largest non-financial companies on NASDAQ) |
| Sector Exposure | Broad: Tech, Healthcare, Financials, Industrials, etc. | Tech-heavy: Apple, Microsoft, NVIDIA, Amazon, etc. |
| Diversification | More diversified | More concentrated (especially in tech) |
| Volatility | Lower | Higher |
| Dividend Yield | Typically higher (~1.3–1.6%) | Lower (~0.5–0.8%) |
| Growth Potential | Slower, more stable | Faster, more aggressive growth |
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S&P 500 ETF (VOO, SPY): ~11–12%
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NASDAQ ETF (QQQ): ~14–16%
Suggested Strategy
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Balanced approach: Some investors split 60% S&P 500 and 40% NASDAQ to balance stability with growth.
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Dollar-cost averaging: Invest over time to reduce timing risk.
| Index / ETF | Annualized Return (20-Year) | Notes |
|---|---|---|
| S&P 500 (e.g., VOO, SPY) | ~9.5% – 10.0% | Includes broad US market exposure |
| NASDAQ-100 (e.g., QQQ) | ~12.5% – 13.5% | Strong tech-driven performance |
| Feature | SPYL | CSPX |
|---|---|---|
| Full Name | SPDR S&P 500 UCITS ETF (Acc) | iShares Core S&P 500 UCITS ETF (Acc) |
| Ticker Symbol | SPYL | CSPX |
| Domicile | Ireland (UCITS) | Ireland (UCITS) |
| Index Tracked | S&P 500 Index | S&P 500 Index |
| Structure | Accumulating (dividends reinvested) | Accumulating (dividends reinvested) |
| Launch Date | 31 Oct 2023 (newer fund) | 19 May 2010 (long track record) |
| Assets Under Management (AUM) | ~€9.9 bn | ~€106 bn |
| Expense Ratio (TER) | 0.03% p.a. (cheapest UCITS S&P 500) | 0.07% p.a. |
| Replication Method | Physical (optimised sampling) | Physical (optimised sampling) |
| Liquidity / Trading Volume | Growing, but lower than CSPX | Very high, extremely liquid |
| Popularity | Gaining traction, attractive due to low fees | Most popular UCITS S&P 500 ETF, widely used in SG/EU |
| Best For | Cost-sensitive investors who want the cheapest fee | Investors wanting liquidity, proven history, tight spreads |
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SPYL = lowest fee, but newer and smaller.
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CSPX = more expensive, but highly liquid with a 15-year proven track record.
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