Account

In general [§1.1471-5(b)(1)]
Except as otherwise provided in this paragraph (b), the term financial account means-
(1)(i) Depository account [§1.1471-5(b)(1)(i)]
Any depository account (as defined in paragraph (b)(3)(i) of this section) maintained by a financial institution;
(1)(ii) Custodial account [§1.1471-5(b)(1)(ii)]
Any custodial account (as defined in paragraph (b)(3)(ii) of this section) maintained by a financial institution;
(1)(iii) Equity or debt interest [§1.1471-5(b)(1)(iii)]
(iii)(A) Equity or debt interests in an investment entity [§1.1471-5(b)(1)(iii)(A)]
Any equity or debt interest (other than interests regularly traded on an established securities market under paragraph (b)(3)(iv) of this section) in an investment entity described in paragraph (e)(4)(i)(B) or (C) of this section (including an entity that is also a depository institution, custodial institution, insurance company, or investment entity described in paragraph (e)(4)(i)(A) of this section);
(iii)(B) Certain equity or debt interests in a holding company or treasury center [§1.1471-5(b)(1)(iii)(B)]
Any equity or debt interest (other than interests regularly traded on an established securities market under paragraph (b)(3)(iv) of this section) in a holding company or treasury center described in paragraph (e)(1)(v) of this section if-
(1) The expanded affiliated group of which the entity is a member includes one or more investment entities described in paragraph (e)(4)(i)(B) or (C) of this section 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 expanded affiliated group; [§1.1471-5(b)(1)(iii)(B)(1)]
(2) [Reserved]. For further guidance, see §1.1471-5T(b)(1)(iii)(B)(2). [§1.1471-5(b)(1)(iii)(B)(2)]
The return earned on the interest is determined, directly or indirectly, primarily by reference to one or more investment entities described in paragraph (e)(4)(i)(B) or (C) of this section or one or more passive NFFEs that are members of the entity’s expanded affiliated group (as determined under paragraph (b)(3)(vi) of this section);
(3) 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 (as determined under paragraph (b)(3)(v)) of this section); or [§1.1471-5(b)(1)(iii)(B)(3)]
(4) The interest is issued with a principal purpose of avoiding the reporting or withholding requirements of chapter 4; [§1.1471-5(b)(1)(iii)(B)(4)]
(iii)(C) Equity or debt interests in other financial institutions [§1.1471-5(b)(1)(iii)(C)]
Any equity or debt interest (other than interests regularly traded on an established securities market under paragraph (b)(3)(iv) of this section) in an entity that is a depository institution, custodial institution, investment entity described in paragraph (e)(4)(i)(A) of this section, or insurance company if-
(1) 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 (as determined under paragraph (b)(3)(v) of this section); or [§1.1471-5(b)(1)(iii)(C)(1)]
(2) The interest is issued with a principal purpose of avoiding the reporting or withholding requirements of chapter 4. [§1.1471-5(b)(1)(iii)(C)(2)]
(1)(iv) Insurance and annuity contracts [§1.1471-5(b)(1)(iv)]
A contract issued or maintained by an insurance company, a holding company (as described in paragraph (e)(5)(i)(C) of this section) of an insurance company, or a financial institution described in paragraphs (e)(1)(i), (ii), (iii), or (v) of this section, if the contract is a cash value insurance contract (as defined in paragraph (b)(3)(vii) of this section) or an annuity contract.

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