A legal person or a legal arrangement, such as a corporation, organisation, partnership, trust or foundation. It does not include a Sole Trader, who are treated as Private Individuals under CRS/FATCA.
Excepted Foreign Financial Institution (FFI)
Entities which are excluded from the FFI definition and not subject to withholding including:
- Holding companies engaged in non-FI business
- Start-up companies for non-financial business
- Liquidating or reorganizing non-financial entities
- Group hedge/financial company which is non-financial and restricted to affiliates
- Organised in US Territory
Excepted Non-Financial Foreign Entity (Excepted NFFE)
An NFFE that is a:
(A) Publically Traded Corporation; OR
(B) Affiliate of Publically Traded Corporation; OR
(C) Territory NFFE; OR
(D) Holding, Treasury, or Captive Finance Company for Non‐Financial Group; OR
(E) Non‐Financial Start‐up Company; OR
(F) Non‐Financial Entity in Liquidation or Bankruptcy; OR
(G) Inter‐Affiliate FFI; OR
(H) Non‐Profit Organisation.
Any other specifically identified class, including those posing a low risk of tax evasion, as determined by the IRS.
Exempt Beneficial Owner
The term Exempt Beneficial Owner means any of the following persons:
(A) Any Foreign Government, any political subdivision of a Foreign Government, or any wholly owned agency or instrumentality of any one or more of the foregoing; OR
(B) Any International Organisation or any wholly owned agency or instrumentality thereof; OR
(C) Any Foreign Central Bank of Issue; OR
(D) Any Government of U.S. Territory; OR
(E) Certain Retirement Funds; OR
(F) Entities wholly owned by one or more other Exempt Beneficial Owners; OR
(G) In addition, an Exempt Beneficial Owner includes any person treated as an Exempt Beneficial Owner pursuant to a Model 1 IGA or Model 2 IGA.