of the shares (and any disproportionate class of shares) of which are primarily and regularly traded on an established securities market in the United States, and (ii) the entity meets the requirements of clause (ii) of subparagraph (B). (E) Only indirect ownership through qualifying intermediaries counted (i) In general Stock in an entity owned by a person indirectly through 1 or more other persons shall not be treated as owned by such person in determining whether the person meets the requirements of subparagraph (B)(i) or (D)(i) unless all such other persons are qualifying intermediate owners. (ii) Qualifying intermediate owners The term qualifying intermediate owner means a person that is— (I) a qualified resident of Taiwan, or (II) a resident of any other foreign country (other than a foreign country that is a foreign country of concern) that has in effect a comprehensive convention with the United States for the avoidance of double taxation. (iii) Special rule for qualified subsidiaries For purposes of applying subparagraph (D)(i), the term qualifying intermediate owner shall include any person who is a United States person who meets such requirements with respect to the United States as determined by the Secretary to be equivalent to the requirements of this subsection (determined without regard to paragraph (1)(B)) with respect to residents of Taiwan. (F) Certain payments not included In determining whether the requirements of subparagraph (B)(ii) or (D)(ii) are met with respect to an entity, the following payments shall not be taken into account: (i) Arm’s-length payments by the entity in the ordinary course of business for services or tangible property. (ii) In the case of a tested group, intra-group transactions. (3) Dual residents (A) Rules for determination of status (i) In general An individual who is an applicable dual resident and who is described in subparagraph (B), (C), or (D) shall be treated as a qualified resident of Taiwan. (ii) Applicable dual resident For purposes of this paragraph, the