Given New Zealand has an income tax treaty with the United States, it appears New Zealand superannuation and KiwiSaver funds will generally fall under the definition of "exempt beneficial owners".
“The proposed Inter-Governmental Agreement (IGA), currently being negotiated between New Zealand and the United States, will still be important for financial institutions and managed funds other than superannuation and KiwiSaver funds.
“It does not appear, however, that superannuation and KiwiSaver funds will have to rely on there being an exemption set out in the IGA, although it is likely to contain such an exemption in order to provide both clarity and comprehensive coverage of the IGA.”
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