specified United States person
(3) Specified United States person Except as otherwise provided by the Secretary, the term “specified United States person” means any United States person other than— (A) any corporation the stock of which is regularly traded on an established securities market, (B) any corporation which is a member of the same expanded affiliated group (as defined in section 1471(e)(2) without regard to the last sentence thereof) as a corporation the stock of which is regularly traded on an established securities market, (C) any organization exempt from taxation under section 501(a) or an individual retirement plan, (D) the United States or any wholly owned agency or instrumentality thereof, (E) any State, the District of Columbia, any possession of the United States, any political subdivision of any of the foregoing, or any wholly owned agency or instrumentality of any one or more of the foregoing, (F) any bank (as defined in section 581 ), (G) any real estate investment trust (as defined in section 856 ), (H) any regulated investment company (as defined in section 851 ), (I) any common trust fund (as defined in section 584(a) ), and (J) any trust which— (i) is exempt from tax under section 664(c), or (ii) is described in section 4947(a)(1).