Tax-exempt entity
(2) Tax-exempt entity. A tax-exempt entity is (i) Any entity that is exempt from tax under section 501(a) or section 529; (ii) A charitable remainder annuity trust or charitable remainder unitrust as defined in section 664(d); (iii) The United States, the government of a possession of the United States, a state, the District of Columbia, the government of a foreign country, or a political subdivision of any of the foregoing; (iv) An Indian Tribal Government as defined in section 7701(a)(40), a subdivision of an Indian Tribal Government determined in accordance with section 7871(d), or an agency or instrumentality of an Indian Tribal Government or subdivision thereof; (v) An Indian Tribal Corporation organized under section 17 of the Indian Reorganization Act of 1934, 25 U.S.C. 477, or section 3 of the Oklahoma Welfare Act, 25 U.S.C. 503; (vi) An international organization as defined in section 7701(a)(18); (vii) An entity any portion of whose income is excluded under section 115; or (viii) An entity that would not be taxable under the Internal Revenue Code for reasons substantially similar to those applicable to any entity listed in this paragraph (c)(2) unless otherwise explicitly made exempt from the application of this section by statute or by action of the Commissioner. (3) Substantially all. The term substantially all has the same meaning as under section 368(a)(1)(C).