The tax imposed by this section shall be paid ½ by the transferor and ½ by the transferee. (2) Exceptions (A) Property transferred to tax-exempt In the case of property transferred to a tax exempt entity, or a State or local government (or political subdivision thereof), the tax imposed by this section shall be zero. (B) Property transferred by tax-exempt In the case of property transferred by a tax-exempt entity, or a State or local government (or political subdivision thereof), the tax imposed by this section shall be paid by the transferee. (C) Tax exempt entity For purposes of this section, the term tax-exempt entity means any organization which is exempt from the tax imposed by this chapter unless such property is used predominantly in an unrelated trade or business the income of which is subject to tax under section 511. (d) Regulations The Secretary shall prescribe such rules as may be necessary or appropriate to prevent avoidance of the purposes of this section. 5000E–2. Real property secrecy transfer tax (a) In general In the case of a sale or exchange of real property to or from an applicable anonymous entity, there is hereby imposed on such transfer a tax equal to $10 for each $100 realized on such sale or exchange. (b) Applicable anonymous taxpayer (1) In general For purposes of this section, the term applicable anonymous entity means any entity or trust the beneficial owners of which are not available by freely accessible public records. (2) Beneficial owner The term beneficial owner means, with respect to any entity, an individual who has any ownership interest in the entity and— (A) exercises control over the entity, (B) owns equity interest in such entity, or (C) receives substantial economic benefits from such entity (other than in connection with employment). (3) Special rule for entities registered in global legal identifier program (A) In general Paragraph (1) shall not apply to any entity that participates in the legal entity identifier program. (B) Controlled groups In the case of any