Acta Francisci Pp. 695

which (including debt interests in excess of $50,000) are held by or through one or more exempt beneficial owners, Active NFFEs de- scribed 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; or

b) An Investment Entity that is a qualified collective investment vehicle under relevant U.S. Treasury Regulations; the reporting obligations of any Investment Entity that is a

HS/VCS Financial Institution (other than a Financial Institution through which interests in the collective investment vehicle are held) shall be deemed fulfilled.

3. With respect to interests in an Investment Entity established in the Holy See or the Vatican City State that is not described in paragraph E or subparagraph F(2) of this section, consistent with paragraph 4 of Article 5 of the Agreement, the reporting obligations of all other Investment Entities with respect to such interests shall be deemed fulfilled if the information required to be reported by the first-mentioned Investment Entity pursuant to the Agreement with respect to such interests is re- ported by such Investment Entity or another person.

V. Accounts Excluded from Financial Accounts. The following accounts are ex- cluded from the definition of Financial Accounts and therefore shall not be treat- ed as U.S. Reportable Accounts.

A. Certain Savings Accounts.

1. Retirement and Pension Account. A retirement or pension account main- tained in the Vatican City State that satisfies the following requirements under the laws of the Holy See or the Vatican City State.

a) The account is subject to regulation as a personal retirement account or is part of a registered or regulated retirement or pension plan for the provision of retirement or pension benefits (including disability or death benefits);

b) The account is tax-favored (i.e., contributions to the account that would otherwise be subject to tax under the laws of the Holy See or

the Vatican City State are deductible or excluded from the gross in-

come of the account holder or taxed at a reduced rate, or taxation of

investment income from the account is deferred or taxed at a reduced

rate);