non-consenting U.S. accounts
(8) Non-consenting U.S. accounts. The term non-consenting U.S. accounts has the meaning set forth in an applicable Model 2 IGA. (9) Offshore obligation. The term offshore obligation means an offshore obligation defined in 1.6049-5(c)(1). For the definition of the term obligation, see paragraph (f)(3) of this section. (10) Participating FFI. The term participating FFI means an FFI that is described in 1.1471-1(b)(91). (11) Recalcitrant account holder. The term recalcitrant account holder has the same meaning set forth in 1.1471-1(b)(110). (12) Registered deemed-compliant FFI. The term registered deemed-compliant FFI means an FFI that is described in 1.1471-1(b)(111). (13) Reporting Model 1 FFI. The term reporting Model 1 FFI means an FFI that is described in 1.1471-1(b)(114). (14) Reporting Model 2 FFI. The term reporting Model 2 FFI means a participating FFI that is described in 1.1471-1(b)(91). (15) Withholdable payment. The term withholdable payment means a payment described in 1.1471-1(b)(145). (16) Paid and received outside the United States(i) In general. Except as otherwise provided in paragraphs (f)(16)(ii) and (iii) of this section, the term paid and received outside the United States means an amount that is paid by a payor or middleman outside the United States as described in 1.6049-5(e). (ii) Transfers to the United States. Without regard to the location of the account from which the amount is drawn, an amount that is described in paragraph (f)(16)(ii)(A) or (B) of this section and paid by transfer to an account maintained by the payee in the United States or by mail to a United States address (including an amount paid with respect to a bond or a discount obligation described in 1.6049-5(e)(4)) is not considered to be paid and received outside the United States. (A) An amount is described in this paragraph (f)(16)(ii)(A) if it is paid by an issuer or the paying agent of the issuer with respect to an obligation that is