Deemed-Compliant Financial Institutions. The following categories of institutions are Non-Reporting [FATCA Partner] Financial Institutions that are treated as deemed-compliant FFIs for purposes of section 1471 of the U.S. Internal Revenue Code:
Deemed-Compliant Financial Institutions. A. Registered Deemed-Compliant Financial Institutions. The following categories of institutions are Non-Reporting Swiss Financial Institutions that are treated as registered deemed-compliant FFIs for purposes of section 1471 of the U.S. Internal Revenue Code:
Deemed-Compliant Financial Institutions. The following categories of institutions are Non-Reporting Irish Financial Institutions that are treated as deemed-compliant FFIs for purposes of section 1471 of the U.S. Internal Revenue Code:
Deemed-Compliant Financial Institutions. A. Deemed-Compliant Financial Institutions The following Financial Institutions are treated as Non-Reporting Netherlands Financial Institutions and as deemed-compliant FFIs for purposes of section 1471 of the U.S. Internal Revenue Code:
Deemed-Compliant Financial Institutions.
(1) Where an Entity determines that it is to be treated as a Deemed-Compliant Bahamas Financial Institution under Annex II to the Agreement, the provisions of this Act shall apply to that Entity, with such modifications as the circumstances require, only to the extent that the Agreement imposes due diligence and reporting obligations on the Entity.
(2) The Entities referred to under subsection (1) are —
(a) Financial institution with a local client base;
(b) Local bank;
(c) Financial Institution with only low value accounts;
(d) Qualified Credit Card Issuer;
(e) Trustee - Documented Trust;
(f) Sponsored Investment Entity;
(g) Sponsored Controlled Foreign Corporation;
(h) Sponsored, Closely Held Investment Vehicle;
(i) Investment Advisor;
(j) Investment Manager; or
(k) Collective Investment Vehicle.
Deemed-Compliant Financial Institutions. A. The following categories of institutions are Non-Reporting German Financial Institutions that are treated as deemed-compliant FFIs for purposes of section 1471 of the U.S. Internal Revenue Code: A German Financial Institution that meets all of the following requirements:
a) The Financial Institution must be licensed and regulated under the laws of the Federal Republic of Germany;
b) The Financial Institution must have no fixed place of business outside the Federal Republic of Germany;
c) The Financial Institution must not solicit account holders outside the Federal Republic of Germany. For this purpose, a Financial Institution shall not be considered to have solicited account holders outside of the Federal Republic of Germany merely because it operates a website, provided that the website does not specifically indicate that the Financial Institution provides accounts or services to nonresidents or otherwise target or solicit U.S. customers;
d) The Financial Institution must be required under the tax laws of the Federal Republic of Germany to perform either information reporting or withholding of tax with respect to accounts held by residents of the Federal Republic of Germany;
e) At least 98 percent of the accounts by value provided by the Financial Institution must be held by residents (including residents that are entities) of the Federal Republic of Germany or another Member State of the European Union;
f) Subject to subparagraph 1(g), below, beginning on January 1, 2014, the Financial Institution does not maintain accounts for
(i) any Specified U.S. Person who is not a resident of the Federal Republic of Germany (including a U.S. Person that was a resident of the Federal Republic of Germany when the account was opened but subsequently ceases to be a resident of the Federal Republic of Germany),
(ii) a Nonparticipating Financial Institution, or
(iii) any Passive NFFE with Controlling Persons who are U.S. citizens or residents;
g) On or before January 1, 2014, the Financial Institution must implement policies and procedures to monitor whether it provides any account held by a person described in subparagraph 1(f), and if such an account is discovered, the Financial Institution must report such account as though the Financial Institution were a Reporting German Financial Institution or close such account;
h) With respect to each account that is held by an individual who is not a resident of the Federal Republic of Germany or by an entity, and that is o...
Deemed-Compliant Financial Institutions. The following categories of institutions are Non-Reporting Mexican Financial Institutions that are treated as deemed-compliant FFIs for purposes of section 1471 of the U.S. Internal Revenue Code:
A. Any exempt organization resident of Mexico entitled to the benefits provided in Article 22 of the Convention between the Government of the United States of America and the Government of the United Mexican States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and paragraph 17 of its Protocol.
B. Consistent with paragraph 3 of Article 5, a fideicomiso, to the extent that the fiduciaria of the fideicomiso is a Reporting Mexican Financial Institution and reports any information required to be obtained and exchanged pursuant to this Agreement with respect to any Controlling Person of the fideicomiso.
C. A fideicomiso that serves solely as escrow for a debt or purchase obligation of the settlor.
D. A fideicomiso the assets of which consist solely of real property.
E. In the case of an Investment Entity that is a collective investment vehicle regulated under the laws of Mexico,
a. if all of the interests in the collective investment vehicle (including debt interests in excess of fifty thousand dollars ($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; and
b. if the collective investment vehicle is not described in paragraph (a), consistent with paragraph 3 of Article 5 of the Agreement, 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 required to report with respect to the interests in the collective investment vehicle will be deemed fulfilled with respect to such interests.
Deemed-Compliant Financial Institutions. The following categories of institutions are Non-Reporting Italian Financial Institutions that are treated as deemed-compliant FFIs for purposes of section 1471 of the U.S. Internal Revenue Code:
(i) Local Financial Institutions. An Italian Financial Institution that meets all of the following requirements:
(a) The Financial Institution must be licensed and regulated under the laws of Italy;
(b) The Financial Institution must have no fixed place of business outside Italy;
(c) The Financial Institution must not solicit account holders outside Italy. For this purpose, a Financial Institution shall not be considered to have solicited account holders outside Italy merely because it operates a website, provided that the website does not specifically indicate that the Financial Institution provides accounts or services to nonresidents or otherwise target or solicits U.S. customers;
(d) The Financial Institution must be required under the Italian tax laws to perform either information reporting or withholding of tax with respect to accounts held by residents of Italy;
(e) At least 98 percent of the accounts by value provided by the Financial Institution must be held by residents (including residents that are entities) of Italy or another Member State of the European Union;
(f) Subject to subparagraph (g), below, beginning on July 1, 2014, the Financial Institution does not provide accounts to (i) any Specified U.S. Person who is not a resident of Italy (including a U.S. person that was a resident of Italy when the account was opened but subsequently ceases to be a resident of Italy), (ii) a Nonparticipating Financial Institution, or (iii) any Passive NFFE with Controlling Persons who are U.S. citizens or residents;
(g) On or before July 1, 2014, the Financial Institution must implement policies and procedures to monitor whether it provides any account held by a person described in subparagraph (f), and if such an account is discovered, the Financial Institution must report such account as though the Financial Institution were a Reporting Italian Financial Institution or close such account;
(h) With respect to each account that is held by an individual who is not an Italian resident, and that is opened prior to the date that the Financial Institution implements the policies and procedures described in subparagraph (g) above, the Financial Institution must review those accounts in accordance with the procedures described in Annex I applicable to Preexisting Account...
Deemed-Compliant Financial Institutions. A. Registered Deemed-Compliant Financial Institutions. The following categories of institutions are Non-Reporting Swiss Financial Institutions that are treated as
Deemed-Compliant Financial Institutions. The following Financial Institutions are Non-Reporting French Financial Institutions that are treated as deemed-compliant FFIs for purposes of section 1471 of the U.S. Internal Revenue Code. In addition, paragraph C of this section provides special rules applicable to an Investment Entity.
