Owner

FATCA

The term owner means a person described in §1.1473-1(b)(1), without regard to whether such person is a U.S. person and without regard to whether such person owns a ten percent interest in the entity. The term also includes a person that owns a discretionary interest in a trust and receives a distribution during the calendar year.

Definition [§1.1473-1(b)(1)]

Except as otherwise provided in paragraph (b)(4) or (5) of this section, the term substantial United States owner (or substantial U.S. owner) means:

(1)(i) With respect to any foreign corporation, any specified U.S. person that owns, directly or indirectly, more than 10 percent of the stock of such corporation (by vote or value); [§1.1473-1(b)(1)(i)]

(1)(ii) With respect to any foreign partnership, any specified U.S. person that owns, directly or indirectly, more than 10 percent of the profits interests or capital interests in such partnership; and [§1.1473-1(b)(1)(ii)]

(1)(iii) In the case of a trust-[§1.1473-1(b)(1)(iii)]

(iii)(A) Any specified U.S. person treated as an owner of any portion of the trust under sections 671 through 679; and [§1.1473-1(b)(1)(iii)(A)]

(iii)(B) Any specified U.S. person that holds, directly or indirectly, more than 10 percent of the beneficial interests of the trust. [§1.1473-1(b)(1)(iii)(B)]

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