EFTA Document EFTA01377774

S-1/A a foreign person 50% or more of whose gross income from certain periods is effectively connected with a U.S. trade or business; or a foreign partnership if at any time during its tax year (a) one or more of its partners are U.S. persons who, in the aggregate, hold more than 50% of the income or capital interests of the partnership or (b) the foreign partnership is engaged in a U.S. trade or business; information reporting will apply unless the broker has documentary evidence in its f