Certain Collective Investment Vehicles. In the case of an Investment Entity that is a collective investment vehicle regulated under the laws of Ireland: a) if all of the interests in the collective investment vehicle (including debt interests in excess of $50,000) are held by or through one or more Financial Institutions that are not Nonparticipating Financial Institutions, such collective investment vehicle will be treated as a deemed-compliant FFI for purposes of section 1471 of the U.S. Internal Revenue Code, and the reporting obligations of any Investment Entity (other than a Financial Institution through which interests in the collective investment vehicle are held) will be deemed fulfilled with respect to interests in the collective investment vehicle; or b) if the collective investment vehicle is not described in paragraph a), consistent with paragraph 3 of Article 5 of the Agreement, and if the information required to be reported by the collective investment vehicle under the Agreement with respect to interests in the collective investment vehicle is reported by the collective investment vehicle or another Investment Entity, the reporting obligations of all other Investment Entities which have an obligation to report with respect to the interests in the collective investment vehicle will be deemed fulfilled with respect to such interests.
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Samples: Agreement Between the Government of Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement Fatca, Agreement Between the Government of Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement Fatca, Agreement Between the Government of Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement Fatca
Certain Collective Investment Vehicles. In the case of an Investment Entity that is a collective investment vehicle regulated under the laws of IrelandDenmark:
a) if all of the interests in the collective investment vehicle (including debt interests in excess of $50,000) are held by or through one or more Financial Institutions that are not Nonparticipating Financial Institutions, such collective investment vehicle will be treated as a deemed-compliant FFI for purposes of section 1471 of the U.S. Internal Revenue Code, and the reporting obligations of any Investment Entity (other than a Financial Institution through which interests in the collective investment vehicle are held) will be deemed fulfilled with respect to interests in the collective investment vehicle; or
b) if the collective investment vehicle is not described in paragraph (a), consistent with paragraph 3 of Article 5 of the Agreement, and if the information required to be reported by the collective investment vehicle under the Agreement with respect to interests in the collective investment vehicle is reported by the collective investment vehicle or another Investment Entity, the reporting obligations of all other Investment Entities which have an obligation required to report with respect to the interests in the collective investment vehicle will be deemed fulfilled with respect to such interests.
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Samples: International Tax Compliance Agreement, International Tax Compliance Agreement
Certain Collective Investment Vehicles. In the case of an Investment Entity that is a collective investment vehicle regulated under the laws of IrelandDenmark:
a) if all of the interests in the collective investment vehicle (including debt interests in- terests in excess of $50,000) are held by or through one or more Financial Institutions In- stitutions that are not Nonparticipating Financial Institutions, such collective investment vehicle will be treated as a deemed-compliant FFI for purposes of section 1471 of the U.S. Internal Revenue Code, and the reporting obligations of any Investment Entity (other than a Financial Institution through which interests in- terests in the collective investment vehicle are held) will be deemed fulfilled with respect to interests in the collective investment vehicle; or
b) if the collective investment vehicle is not described in paragraph (a), consistent con- sistent with paragraph 3 of Article 5 of the Agreement, and if the information required re- quired to be reported by the collective investment vehicle under the Agreement Agree- ment with respect to interests in the collective investment vehicle is reported by the collective investment vehicle or another Investment Entity, the reporting report- ing obligations of all other Investment Entities which have an obligation required to report with respect to the interests in the collective investment vehicle will be deemed fulfilled with respect to such interests.
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Certain Collective Investment Vehicles. In the case of an Investment Entity that is a collective investment vehicle regulated under the laws of IrelandSpain:
a) if all of the interests in the collective investment vehicle (including debt interests in excess of $50,000) are held by or through one or more Financial Institutions that are not Nonparticipating Financial Institutions, such collective investment vehicle will be treated as a deemed-compliant FFI for purposes of section 1471 of the U.S. Internal Revenue Code, and the reporting obligations of any Investment Entity (other than a Financial Institution through which interests in the collective investment vehicle are held) will be deemed fulfilled with respect to interests in the collective investment vehicle; or
b) if the collective investment vehicle is not described in paragraph (a), consistent with paragraph 3 of Article 5 of the Agreement, and if the information required to be reported by the collective investment vehicle under the Agreement with respect to interests in the collective investment vehicle is reported by the collective investment vehicle or another Investment Entity, the reporting obligations of all other Investment Entities which have an obligation required to report with respect to the interests in the collective investment vehicle will be deemed fulfilled with respect to such interests.
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Certain Collective Investment Vehicles. In the case of an Investment Entity that is a collective investment vehicle regulated under the laws of IrelandNorway:
a) if all of the interests in the collective investment vehicle (including debt interests in excess of $50,000) are held by or through one or more Financial Institutions that are not Nonparticipating Financial Institutions, such collective investment vehicle will be treated as a deemed-compliant FFI for purposes of section 1471 of the U.S. Internal Revenue Code, and the reporting obligations of any Investment Entity (other than a Financial Institution through which interests in the collective investment vehicle are held) will be deemed fulfilled with respect to interests in the collective investment vehicle; or
b) if the collective investment vehicle is not described in paragraph (a), consistent with paragraph 3 of Article 5 of the Agreement, and if the information required to be reported by the collective investment vehicle under the Agreement with respect to interests in the collective investment vehicle is reported by the collective investment vehicle or another Investment Entity, the reporting obligations of all other Investment Entities which have an obligation required to report with respect to the interests in the collective investment vehicle will be deemed fulfilled with respect to such interests.
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Certain Collective Investment Vehicles. In the case of an Investment Entity that is a collective investment vehicle regulated under the laws of Ireland:
a) if all of the interests in the collective investment vehicle (including debt interests in excess of $50,000) are held by or through one or more Financial Institutions that are not Nonparticipating Financial Xxxxx- cial Institutions, such collective investment vehicle will be treated as a deemed-compliant FFI for purposes of section 1471 of the U.S. Internal Revenue Code, and the reporting obligations of any Investment Entity (other than a Financial Institution through which interests in the collective investment vehicle are held) will be deemed fulfilled with respect to interests in the collective investment vehicle; or
b) if the collective investment vehicle is not described in paragraph a), consistent with paragraph 3 of Article 5 of the Agreement, and if the information required to be reported by the collective investment vehicle under the Agreement with respect to interests in the collective investment vehicle is reported by the collective investment vehicle or another Investment Entity, the reporting obligations of all other Investment Entities which have an obligation obli- gation to report with respect to the interests in the collective investment vehicle will be deemed fulfilled with respect to such interests.
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