海外账户纳税法案PPT方案.ppt

* * * 接受存款，接受客户托管金融资产，投资 保险合同中有现金价值的需要纳入范围 金融集团控股公司-集团即使不从事金融活动，但下属企业有金融活动，则整体集团均纳入 Aforeign financial institutionis defined asany foreign entity that: Adepository institution, whichaccepts depositsin the ordinary course of businessand regularly engagesin one or more of thefollowing activities, including: Makes loans; Purchases, sells, discounts, or negotiates accounts receivable, installment obligations, notes, drafts, checks, bills of exchange, acceptances, or other evidences of indebtedness; Issues letters of credit and negotiates drafts drawn thereunder; Provides trust or fiduciary services; Finances foreign exchange transactions;or Enters into, purchases, or disposes of financeleases or leased assets. Not includeentitysolely accepts depositsfrom personsas collateral or security pursuant to a sale or lease of propertyor pursuant to a similar financing arrangement Acustodial institution, whichholds, as asubstantial portionof its business,financial assetsfor the benefit ofone or more other persons; Substantial portion:gross income attributable to holding financial assetsand related financial servicesequals or exceeds 20 percentof the entity’s gross incomeduring theshorter of 3-year periodor period during whichthe entity has been in existence Gross Income: custody, account maintenance, and transfer fees; commissions and fees earnedfrom executing and pricing securities transactions; income earned from extending credit to customerswith respect to financial assets held in custody (or acquired through such extension of credit); income earned on the bid-ask spreadof financial assets;and fees for providing financial adviceand forclearance and settlement services. aninvestment entity, which: primarily conducts as a businessone or more of the following activities or operationsfor or on behalf of a customer: Trading in money market instruments (checks, bills, certificates of deposit, derivatives, etc.); foreign currency; foreign exchange, interest rate, and index ins