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EBOs and deemed-compliant FFIs occupy a special seat at the FATCA table. Under the Code and the IGAs, payments to EBOs are generally exempt from FATCA withholding, and deemed-compliant FFIs are excluded from FATCA withholding and reporting. Under the Treasury regulations, if a certain type of EBO receives a withholdable payment connected with a commercial financing activity, it will not be treated as an EBO for that payment and FATCA withholding will apply. It is unclear whether this commercial financing activity exception applies under the IGAs. The Canadian IGA seemingly provides three opportunities for an entity to qualify as an EBO or a deemed-compliant FFI.