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First, an entity will be treated as an EBO or a deemed-compliant FFI if it is a non-reporting Canadian financial institution and otherwise qualifies as an EBO or a deemed-compliant FFI under either Code and Treasury regulations or the Canadian IGA. Second, an entity may qualify as an EBO or a deemed-compliant FFI under the Canadian IGA. Third, an entity may qualify as an EBO or a deemed-compliant FFI if it is a Canadian retirement plan identified in annex II of the Canadian IGA and otherwise qualifies as an EBO or a deemed-compliant FFI.170 Generally, EBOs are foreign governments, including any political subdivisions or wholly owned agencies thereof, foreign central banks, governments of us territories, certain foreign retirement funds, and certain entities owned by EBOs. Deemed compliant FFIs fall into three major categories under the Treasury regulations: 1. registered deemed-compliant FFI, 2. certified deemed-compliant FFI, and 3. owner-documented FFI. An entity does not automatically qualify as a deemed-compliant FFI under the Code and Treasury regulations; it must take some affirmative action to obtain this status. Yet entities that qualify as EBOs or deemed-compliant FFIs under the Canadian IGA receive more favourable treatment than those qualifying under the Code and regulations, since they are not required to take affirmative action to so qualify. Generally, the rules under the Canadian IGA for EBOs and deemed-compliant FFIs are similar to the rules in the Treasury regulations. As indicated above, there are special rules in the Canadian IGA for Canadian retirement plans. Although the Canadian IGA provides that the United States must treat the Canadian retirement plans in annex II as EBOs or deemed-compliant FFIs under IRC sections 1471 and 1472, this provision is an “as appropriate” clause. Consequently, Canadian retirement plans will qualify as EBOs or deemed-compliant FFIs under article 4(3) of the IGA if they would otherwise meet those definitions. Since the terms “exempt beneficial owner” and “deemed-compliant FFIs” are used in article 4(3) without initial capitals and neither of these terms is defined in the IGA, presumably the definitions in the Code and regulations apply.