definiens: within the meaning of Section 881(c)(3)(A ) of the Code, a of the Borrower within themeaning of Section 881(c)(3)(B ) of the Code, or a described in Section 881(c)(3)(C ) of theCode ( a ) and ( y ) two executed originals of IRS Form W-8BEN - E ; or ( D ) to the extent aForeign Lender is not the beneﬁcial owner, executed originals of IRS Form W-8IMY, accompanied by IRS Form W-8ECI, IRS Form W-8BEN - E, a U.S. Tax Compliance Certiﬁcate, IRS Form W-9, and/or other certiﬁcation documents from eachbeneﬁcial owner, as applicable and ( III ) if a payment made to Lender under this Agreement would be subject to U.S