Exempt Beneficial Owners other than Funds. The following Entities shall be treated as Non-Reporting Singaporean Financial Institutions and as exempt beneficial owners for purposes of sections 1471 and 1472 of the U.S. Internal Revenue Code, other than with respect to a payment that is derived from an obligation held in connection with a commercial financial activity of a type engaged in by a Specified Insurance Company, Custodial Institution, or Depository Institution.
Appears in 7 contracts
Samples: Agreement Between the Government of the Republic of Singapore and the Government of the United States of America to Improve International Tax Compliance and to Implement Fatca, International Tax Compliance Agreement, International Tax Compliance Agreement