Which Beneficial Owner are You?

List of definitions of “beneficial owner”:

  1. 31 C.F.R. §1010.210 AML program
  2. 31 C.F.R. §1010.605 Individual Customer of bank
  3. 31 C.F.R. §1010.230 Entity Customer, AML program
  4. 26 C.F.R. §1.1441-1(c)(6) Foreign person, tax
  5. 31 U.S.C. §5336(a)(3) BOIR Beneficial Owner
  6. 31 C.F.R. §1010. 380(d) BOIR Beneficial Owner

They are doing their very best to conflate and overlap between U.S. Person and Foreign Person–making the thread of “exception” so remote and exclusive, its existence would sound absurd to nearly everyone who hasn’t devoted any time to the subject.

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