INTER-GOVERNMENTAL AGREEMENT AND MEMORANDUM OF UNDERSTANDING (MOU) BETWEEN GOVERNMENT OF INDIA AND GOVERNMENT OF USA TO IMPROVE INTERNATIONAL TAX COMPLIANCE AND TO IMPLEMENT FOREIGN ACCOUNT TAX COMPLIANCE ACT OF USA
held by any person treated as a settlor or beneficiary of all or a portion of the trust, or any other natural person exercising ultimate ... control over an Entity. In the case of a trust, such term means the settlor, the trustees, the protector (if any), the beneficiaries or class