registration-required obligation
(1) Registration-required obligation (A) In general The term “registration-required obligation” has the same meaning as when used in section 163(f), except that such term shall not include any obligation which— (i) is required to be registered under section 149(a), or (ii) is described in subparagraph (B). (B) Certain obligations not included An obligation is described in this subparagraph if— (i) there are arrangements reasonably designed to ensure that such obligation will be sold (or resold in connection with the original issue) only to a person who is not a United States person, (ii) interest on such obligation is payable only outside the United States and its possessions, and (iii) on the face of such obligation there is a statement that any United States person who holds such obligation will be subject to limitations under the United States income tax laws.