High-value accounts.

(C) High-value accounts. Account holders of preexisting accounts maintained by a participating FFI that are high-value accounts (as described in 1.1471-4(c)(5)(iv)(D)) and that are described in paragraph (g)(2) of this section will be treated as recalcitrant account holders beginning on the date that is one year after the effective date of the FFI agreement.


26 CFR § 1.1471-5

Scoping language

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