“ 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.'. ”

“ WITHHOLDING AGENT- The term `withholding agent' means all persons, in whatever capacity acting, having the control, receipt, custody, disposal, or payment of any withholdable payment. ` (5) FOREIGN ENTITY- The term `foreign entity' means any entity which is not a United States person. ”

“ FINANCIAL ACCOUNT- Except as otherwise provided by the Secretary, the term `financial account' means, with respect to any financial institution-- ` (A) any depository account maintained by such financial institution, ` (B) any custodial account maintained by such financial institution, and ` (C) any equity or debt interest in such financial institution (other than interests which are regularly traded on an established securities market) . ”