Canada–United States Enhanced Tax Information Exchange Agreement Implementation Act — C-10.58 A
owing applicable registration requirements on the IRS FATCA registration website) in all reporting completed on the Financial Institution’s behalf; and f) The sponsoring entity has not had its status as a sponsor revoked. E Sponsored, Closely Held Investment Vehicle A Canadian Financial Institution satisfying the following requirements: 1 The Financial Institution is a Financial Institution solely because it is an Investment Entity and is not a qualified intermediary, withholding foreign partnership, or withholding foreign trust pursuant to relevant U.S. Treasury Regulations; 2 The sponsoring entity is a Reporting U.S. Financial Institution, Reporting Model 1 FFI, or Participating FFI, and is authorized to act on behalf of the Financial Institution (such as a professional manager, trustee, or managing partner); 3 The Financial Institution does not hold itself out as an investment vehicle for unrelated parties; 4 Twenty or fewer individuals own all of the debt interests and Equity Interests in the Financial Institution (disregarding debt interests owned by Participating FFIs and deemed-compliant FFIs and Equity Interests owned by an Entity if that Entity owns 100 percent of the Equity Interests in the Financial Institution and is itself a sponsored Financial Institution described in this paragraph E); and 5 The sponsoring entity complies with the following requirements: a) The sponsoring entity has registered as a sponsoring entity with the IRS on the IRS FATCA registration website; b) The sponsoring entity agrees to perform, on behalf of the Financial Institution, all due diligence, reporting, and other requirements (including providing to any immediate payor the information described in subparagraph 1(e) of Article 4 of the Agreement), that the Financial Institution would have been required to perform if it were a Reporting Canadian Financial Institution and retains documentation collected with respect to the Financial Institution for a period of six years; c) The sponsoring entity identifies the Financial Institution in all reporting completed on the Financial Institution’s behalf; and d) The sponsoring entity has not had its status as a sponsor revoked. F Restricted Fund A Financial Institution that qualifies as a restricted fund as described in relevant U.S. Treasury Regulations, applying the procedures set forth in, or required under, Annex I in lieu of the procedures set forth in, or required under, Treasury Regulation section 1.1471-4, and applying references to “report” or “reports” in lieu of references in relevant paragraphs in those regulations to “withhold and report” or “withholds and reports”, provided that the Financial Institution provides to any immediate payor the information described in subparagraph 1(e) of Article 4 of the Agreement, or fulfills the requirements described in subparagraph 1(d) of Article 4 of the Agreement, as applicable. G Labour-Sponsored Venture Capital Corporations prescribed under section 6701 of the Income Tax Regulations . H Any Central Cooperative Credit Society as defined in section 2 of the Cooperative Credit Associations Act and whose accounts are maintained for member financial institutions. I Any entity described in paragraph 3 of Article XXI (Exempt Organizations) of the Convention. J An Investment Entity established in Canada that is regulated as a collective investment vehicle, provided that all of the interests in the collective investment vehicle (including debt interests in excess of $50,000) are held by or through one or more exempt beneficial owners, Active NFFEs described in subparagraph B(4) of section VI of Annex I, U.S. Persons that are not Specified U.S. Persons, or Financial Institutions that are not Nonparticipating Financial Institutions. K Special Rules The following rules apply to an Investment Entity: 1 With respect to interests in an Investment Entity that is a collective investment vehicle described in paragraph J of this section, the reporting obligations