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Under both the Code and the Canadian IGA, a “specified United States person” is subject to FATCA reporting and withholding. A “specified United States person” is a “United States person” other than certain publicly traded corporations, tax-exempt organizations, individual retirement plans, us government entities, us banks, real estate investment trusts, regulated investment companies, common trust funds, and charitable remainder trusts. As discussed above, the Code defines a “United States person” to mean a US citizen or resident, a US corporation or partnership, a US resident estate, or a us trust. The definition in the Canadian IGA is essentially the same, with some variation in wording.63 FATCA introduces over 150 defined terms, which can have different meanings depending on where the entity resides. If an entity is resident in a country with an IGA, the IGA will generally govern. An entity resident in a country without an IGA is governed by the default rules in the Code and the Treasury regulations.