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FATCA classifies every entity into one of two mutually exclusive groups, as an FFI or an NFFE. Certain FFIs and NFFEs must report information regarding the accounts and other ownership interests of us persons or face a 30 percent withholding tax on “withholdable payments”—that is, us-source payments of interest, dividends, royalties, and gross proceeds from sales of assets that can produce US-source interest or dividends. An FFI is a financial institution that is a “foreign entity,” defined as an entity that is not a “United States person.” A “financial institution” is generally defined as an entity that accepts deposits in the ordinary course of a banking or similar business; holds financial assets for the account of others as a substantial portion of its business; or engages primarily in the business of investing, reinvesting, or trading in securities, partnership interests, commodities, or an interest in any of the immediately preceding items.70 The Treasury regulations further divide financial institutions into the following categories: depository institution, custodial institution, investment entity, “insurance company or holding company,” and “holding company or treasury center.” An FFI must enter into an FFi agreement with the IRS and obtain a “global intermediary identification number” (GIIN) in order to avoid FATCA withholding, unless the FFI qualifies for an exclusion.