03.09 – An Equity or Debt Interest in a Holding Company or Treasury Centre of a Financial Group

Any Equity or Debt Interest (other than regularly traded interests) in a Holding Company or Treasury Centre described in Section 2.30 will be a Financial Account where:

  • Its related entities include one or more Investment Entities or Passive NFFEs, and the income derived by such Investment Entities, or Passive NFFEs is 50 percent or more of the aggregate income earned by the related entity group
  • The redemption or retirement amount or return earned on the interest is determined, directly or indirectly, primarily by reference to one or more Investment Entities or one or more Passive NFFEs that are members of the entity’s the related entity group
  • The value of the interest is determined, directly or indirectly, primarily by reference to assets that give rise (or could give rise) to withholdable payments; or
  • The interest is issued with a principal purpose of avoiding the reporting or withholding requirements of Section 4.