686 Acta Apostolicae Sedis - Commentarium Officiale

identified as a U.S. Reportable Account or as an account held by a Nonparticipating Financial Institution, as applicable, as of the date the account was opened.

H. Alternative Procedures for New Entity Accounts Opened after the Determi- nation Date, and before January 1, 2015. For New Entity Accounts opened after the Determination Date, and before January 1, 2015, either with re- spect to all New Entity Accounts or, separately, with respect to any clear- ly identified group of such accounts, the HS/VCS may permit Reporting HS/VCS Financial Institutions to treat such accounts as Preexisting Entity Accounts and apply the due diligence procedures related to Preexisting Entity Accounts specified in section IV of this Annex I in lieu of the due diligence procedures specified in section V of this Annex I. In this case, the due diligence procedures of section IV of this Annex I must be applied with- out regard to the account balance or value threshold specified in paragraph A of section IV of this Annex I.

ANNEX II

The following Entities shall be treated as exempt beneficial owners or deemed-compliant FFIs, as the case may be, and the following accounts are excluded from the definition of Financial Accounts.

This Annex II may be modified by a mutual written decision entered into between the Competent Authorities of the HS/VCS and the United States: (1) to include additional Entities and accounts that present a low risk of being used by U.S. Persons to evade U.S. tax and that have similar characteristics to the Entities and accounts described in this Annex II as of the date of signature of the Agreement; or (2) to remove Entities and accounts that, due to changes in circumstances, no longer present a low risk of being used by U.S. Persons to evade U.S. tax. Any such addition or removal shall be effective on the date of signature of the mutual decision, unless otherwise provided therein. Procedures for reaching such a mutual decision may be included in the mutual agreement or arrangement described in paragraph 6 of Article 3 of the Agreement.

I. Exempt Beneficial Owners other than Funds. The following Entities shall be treated as Non-Reporting HS/VCS Financial Institutions and as exempt benefi- cial owners for purposes of sections 1471 and 1472 of the U.S. Internal Revenue