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IRS.gov Website
Publication 515
taxmap/pubs/p515-011.htm#en_us_publink100015531

Definitions

rule
taxmap/pubs/p515-011.htm#en_us_publink100015473

Chapter 4 withholding rate pool.

rule
A "chapter 4 withholding rate pool" means a pool of payees that are nonparticipating FFIs provided on a chapter 4 withholding statement (as described in Treasury regulations section 1.1471-3(c)(3)(iii)(B)(3) to which a withholdable payment is allocated. The term also means a pool of payees provided on an FFI withholding statement (as described in Treasury regulations section 1.1471-3(c)(iii)(B)(2)) to which a withholdable payment is allocated to (A) a pool of payees consisting of each class of recalcitrant account holders described in Treasury regulations section 1.1471-4(d)(6) (or with respect to an FFI that is a QI, a single pool of recalcitrant account holders), including a separate pool of account holders to which the escrow procedures for dormant accounts apply; or (B) a pool of payees that are U.S. persons as described in Treasury regulations section 1.1471-3(c)(3)(iii)(B)(2) (including such a pool allocated a reportable amount on a withholding statement provided solely for chapter 3 purposes).
taxmap/pubs/p515-011.htm#en_us_publink100015533

Deemed-compliant FFI.

rule
A "deemed-compliant FFI" means an FFI that is treated, pursuant to section 1471(b)(2) and Treasury regulations section 1.1471-5(f), as meeting the requirements of section 1471(b).
taxmap/pubs/p515-011.htm#en_us_publink100015474

Exempt beneficial owner.

rule
An "exempt beneficial owner" is any person described in Treasury regulations section 1.1471-6(b) through (g) and includes any person treated as an exempt beneficial owner under an applicable Model 1 IGA or Model 2 IGA.
taxmap/pubs/p515-011.htm#en_us_publink100015534

Financial institution (FI).

rule
A "financial institution" (FI) is any institution that is a depository institution, custodial institution, investment entity, insurance company (or holding company of an insurance company) that issues cash value insurance or annuity contracts, or a holding company or treasury center that is part of an expanded affiliated group of certain FFIs, and includes a financial institution as defined under an applicable Model 1 IGA or Model 2 IGA. See Treasury regulations section 1.1471-5(e)(1).
taxmap/pubs/p515-011.htm#en_us_publink100015535

Foreign financial institution (FFI).

rule
Except as otherwise provided for certain foreign branches of a U.S. financial institution or territory financial institution, a "foreign financial institution" (FFI) means a financial institution that is a foreign entity. The term foreign financial institution also includes a foreign branch of a U.S. financial institution with a QI agreement in effect.
taxmap/pubs/p515-011.htm#en_us_publink100015536

Limited branch.

rule
In the case of a participating FFI, a "limited branch" means a branch described in Treasury regulations section 1.1471-4(e)(2)(iii). With respect to a reporting Model 2 FFI, a limited branch is a branch of the reporting Model 2 FFI that operates in a jurisdiction that prevents such branch from fulfilling the requirements of a participating FFI or deemed-compliant FFI and that is treated as a nonparticipating FFI pursuant to section 1471(e)(1)(B) of the Code.
taxmap/pubs/p515-011.htm#en_us_publink100015537

Model 1 IGA.

rule
A "Model 1 IGA" means an agreement between the United States or the Treasury Department and a foreign government or one or more foreign agencies to implement FATCA through reporting by financial institutions to such foreign government or agency thereof, followed by automatic exchange of the reported information with the IRS. For a list of jurisdictions treated as having an IGA in effect, see www.irs.gov/Businesses/Corporations/Information-for-Foreign-Financial Institutions.
taxmap/pubs/p515-011.htm#en_us_publink100015538

Model 2 IGA.

rule
A "Model 2 IGA" means an agreement or arrangement between the United States or the Treasury Department and a foreign government or one or more foreign agencies to implement FATCA through reporting by financial institutions directly to the IRS in accordance with the requirements of the FFI agreement, as modified by an applicable Model 2 IGA, supplemented by the exchange of information between such foreign government or agency thereof and the IRS. For a list of jurisdictions treated as having an IGA in effect, see www.irs.gov/Businesses/Corporations/Information-for-Foreign-Financial Institutions.
taxmap/pubs/p515-011.htm#en_us_publink100015475

Non-financial foreign entity (NFFE).

rule
A "non-financial foreign entity" (NFFE) is a foreign entity that is not a financial institution. A NFFE includes a territory NFFE, as defined in Treasury regulations section 1.1471-1(b)(132), and a foreign entity treated as an NFFE pursuant to a Model 1 IGA or Model 2 IGA.
taxmap/pubs/p515-011.htm#en_us_publink100015539

Nonparticipating FFI.

rule
A "nonparticipating FFI" is an FFI other than a participating FFI, a deemed-compliant FFI, or an exempt beneficial owner.
taxmap/pubs/p515-011.htm#en_us_publink100015540

Owner-documented FFI.

rule
An "owner-documented FFI" is an FFI described in Treasury regulations section 1.1471-5(f)(3).
taxmap/pubs/p515-011.htm#en_us_publink100015541

Participating FFI.

rule
A "participating FFI" is an FFI, or branch of an FFI, that has in effect an FFI agreement with the IRS, and includes a reporting Model 2 FFI.
taxmap/pubs/p515-011.htm#en_us_publink100015542

Passive NFFE.

rule
A "passive NFFE" is an NFFE that is not an excepted NFFE. With respect to a reporting Model 2 FFI filing a Form 8966 to report its accounts and payees, a passive NFFE is an NFFE that is not an active NFFE (as defined in the applicable IGA).
taxmap/pubs/p515-011.htm#en_us_publink100015479

Recalcitrant account holder.

rule
A "recalcitrant account holder" is an account holder (other than an account holder that is an FFI or is presumed to be an FFI) of a participating FFI or registered deemed-compliant FFI that has failed to provide the FFI maintaining its account with the information required under Treasury regulations section 1.1471-5(g).
taxmap/pubs/p515-011.htm#en_us_publink100015543

Registered deemed-compliant FFI.

rule
A "registered deemed-compliant FFI " is an FFI described in Treasury regulations section 1.1471-5(f)(1), and includes a reporting Model 1 FFI, a QI branch of a U.S. financial institution that is a reporting Model 1 FFI, and a nonreporting FI treated as a registered deemed-compliant FFI under an applicable IGA.
taxmap/pubs/p515-011.htm#en_us_publink100015544

Reporting Model 1 FFI.

rule
A "reporting Model 1 FFI" is an FI, including a foreign branch of a U.S. financial institution, treated as a reporting financial institution under a Model 1 IGA.
taxmap/pubs/p515-011.htm#en_us_publink100015545

Reporting Model 2 FFI.

rule
A "reporting Model 2 FFI" is an FI or branch of an FI treated as a reporting financial institution under a Model 2 IGA.
taxmap/pubs/p515-011.htm#en_us_publink100015546

Territory financial institution.

rule
A "territory financial institution" is a financial institution that is incorporated or organized under the laws of any U.S. territory, excluding a territory entity that is a financial institution only because it is an investment entity as defined in Treasury regulations section 1.1471-5(e)(4).
taxmap/pubs/p515-011.htm#en_us_publink100015547

Withholdable payment.

rule
A "withholdable payment" is a payment described in Treasury regulations section 1.1473-1(a). See Income Subject to Withholding, earlier, for a discussion of which payments qualify as withholdable payments.