The US Internal Revenue Service (IRS) has released a list of the Japanese and US entities that have been self-certified as investment banks pursuant to the Memorandum of Understanding (MoU) signed by the two countries on 27 December 2005. For a report on the MoU.
The MoU defines the term "investment bank" for purposes of Art. 11(3)(c)(1) (Interest) of the 2003 Japan-Us income tax treaty. The MoU requires the competent authority of each contracting state to noti…