Specific Treatment of Retirement Plans. The United States shall treat as a deemed- compliant FFI or exempt beneficial owner, as appropriate, for purposes of section 1471 of the U.S. Internal Revenue Code Irish retirement plans described and identified in Annex II. For this purpose, an Irish retirement plan includes an entity established or located in and regulated in Ireland, or a predetermined contractual or legal arrangement, operated to provide pension or retirement benefits or earn income for providing such benefits under the laws of Ireland and regulated with respect to contributions, distributions, reporting, sponsorship, and taxation.
Appears in 2 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, International Tax Compliance Agreement
Specific Treatment of Retirement Plans. The United States shall treat as a deemed- compliant FFI or exempt beneficial owner, as appropriate, for purposes of section 1471 of the U.S. Internal Revenue Code Irish retirement plans described and identified in Annex IIXxxxx XX. For this purpose, an Irish retirement plan includes an entity established or located in and regulated in Ireland, or a predetermined contractual or legal arrangement, operated to provide pension or retirement benefits or earn income for providing such benefits under the laws of Ireland and regulated with respect to contributions, distributions, reporting, sponsorship, and taxation.
Appears in 1 contract
Specific Treatment of Retirement Plans. The United States shall treat as a deemed- compliant deemedcompliant FFI or exempt beneficial owner, as appropriate, for purposes of section 1471 of the U.S. Internal Revenue Code Irish retirement plans described and identified in Annex II. For this purpose, an Irish retirement plan includes an entity established or located in and regulated in Ireland, or a predetermined contractual or legal arrangement, operated to provide pension or retirement benefits or earn income for providing such benefits under the laws of Ireland and regulated with respect to contributions, distributions, reporting, sponsorship, and taxation.
Appears in 1 contract
Specific Treatment of Retirement Plans. The United States shall treat as a deemed- deemed-compliant FFI or exempt beneficial owner, as appropriate, for purposes of section 1471 of the U.S. Internal Revenue Code Irish retirement plans described and identified in Annex II. For this purpose, an Irish retirement plan includes an entity established or located in and regulated in Ireland, or a predetermined prede- termined contractual or legal arrangement, operated to provide pension or retirement benefits or earn income for providing such benefits under the laws of Ireland and regulated with respect to contributions, distributions, reporting, sponsorship, and taxation.
Appears in 1 contract