Passive NFFE. A “Passive NFFE” means any NFFE that is not (i) an Active NFFE, or (ii) a withholding foreign partnership or withholding foreign trust pursuant to relevant U.S. Treasury Regulations.
Appears in 133 contracts
Samples: Income Tax Agreement, International Tax Compliance Agreement, International Tax Compliance Agreement
Passive NFFE. A “Passive NFFE” means any NFFE that is not (i) an Active NFFE, NFFE or (ii) a withholding foreign partnership or withholding foreign trust pursuant to relevant U.S. Treasury Regulations.
Appears in 10 contracts
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, International Tax Compliance Agreement
Passive NFFE. A “Passive NFFE” means any NFFE that is not (i) neither an Active NFFE, or (ii) nor a withholding foreign partnership or withholding foreign trust pursuant to relevant U.S. Treasury Regulations.
Appears in 6 contracts
Samples: Cooperation Agreement, Cooperation Agreement, Cooperation Agreement
Passive NFFE. A “"Passive NFFE” " means any NFFE that is not (i) an Active NFFE, or (ii) a withholding foreign partnership or withholding foreign trust pursuant to relevant U.S. Treasury Regulations.
Appears in 3 contracts
Samples: Inter Governmental Agreement and Memorandum of Understanding (Mou), Term of Agreement, Inter Governmental Agreement and Memorandum of Understanding (Mou)
Passive NFFE. A “Passive NFFE” means any an NFFE that is not other than an excepted NFFE (i) or, in the case of a reporting Model 2 FFI, an Active active NFFE), or (ii) a qualified intermediary, a withholding foreign partnership or partnership, a withholding foreign trust pursuant to relevant U.S. Treasury Regulationstrust, or an exempt beneficial owner.
Appears in 2 contracts
Samples: Ffi Agreement, Ffi Agreement
Passive NFFE. A “Passive NFFE” means any NFFE that is not (i) an Active NFFE, or (ii) a withholding foreign partnership or withholding foreign trust pursuant pur- suant to relevant U.S. Treasury Regulations.
Appears in 1 contract
Samples: Agreement for the Exchange of Information Relating to Taxes
Passive NFFE. A “Passive NFFE” means any NFFE that is not (i) an Active NFFE, Ac- tive NFFE or (ii) a withholding foreign partnership or withholding foreign trust pursuant to relevant U.S. Treasury Regulations.
Appears in 1 contract
Passive NFFE. A “Passive NFFE” means any NFFE that is not (i) an Active NFFE, or (ii) a withholding foreign partnership or withholding foreign trust pursuant to relevant U.S. Treasury Regulations.
Appears in 1 contract
Samples: Cooperation Agreement
