Treaty Qualified Retirement Fund classification clarified for CRS reporting, distinguishing FATCA and non US reportable account treatment. Clarification explains that a Treaty Qualified Retirement Fund, while non-reporting under FATCA, is not non-reporting under the CRS and therefore must not be treated as non-reporting for non U.S. reportable accounts; a non-public fund of the armed forces is an active non-financial entity under the CRS and not a financial institution for non U.S. reportable accounts; and gratuity funds may be passive NFEs or reporting financial institutions depending on management, with certain accounts qualifying as excluded accounts if they meet retirement or conditional withdrawal conditions and monetary limits.
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Provisions expressly mentioned in the judgment/order text.
Treaty Qualified Retirement Fund classification clarified for CRS reporting, distinguishing FATCA and non US reportable account treatment.
Clarification explains that a Treaty Qualified Retirement Fund, while non-reporting under FATCA, is not non-reporting under the CRS and therefore must not be treated as non-reporting for non U.S. reportable accounts; a non-public fund of the armed forces is an active non-financial entity under the CRS and not a financial institution for non U.S. reportable accounts; and gratuity funds may be passive NFEs or reporting financial institutions depending on management, with certain accounts qualifying as excluded accounts if they meet retirement or conditional withdrawal conditions and monetary limits.
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