“ Subtitle A—Foreign Account Tax Compliance Part I—INCREASED DISCLOSURE OF BENEFICIAL OWNERS Part II—UNDER REPORTING WITH RESPECT TO FOREIGN ASSETS Part III—OTHER DISCLOSURE PROVISIONS Part IV—PROVISIONS RELATED TO FOREIGN TRUSTS Part V—SUBSTITUTE DIVIDENDS AND DIVIDEND EQUIVALENT PAYMENTS RECEIVED BY FOREIGN PERSONS TREATED AS DIVIDENDS Subtitle B—Delay in Application of Worldwide Allocation of Interest SEC. 551. ”