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Pooled basis reporting will not be out there for payments to sure account holders, resembling nonqualified intermediaries, flow-via entities (mentioned earlier) and certain of their account holders and owners, private arrangement intermediaries, and, in sure circumstances, certified intermediaries, withholding international partnerships, and withholding overseas trusts.
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The account holder (whether or not an individual or an entity) has provided standing directions to make payments with respect to an offshore obligation to an address in, or an account maintained in, the United States, unless the account holder supplies a reasonable clarification in writing that helps its overseas status or offers documentary proof supporting its overseas status.
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