### Question
Can you define what recalcitrant account holder means?


### Answer
**Recalcitrant account holder** is defined as the following in *26 U.S.C. § 1471*:

> any account holder which—


(A) fails to comply with reasonable requests for the information referred to in subsection (b)(1)(A) or (c)(1)(A), or


(B) fails to provide a waiver described in subsection (b)(1)(F) upon request

#### Citation:
  - *26 U.S.C. § 1471*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 4-TAXES TO ENFORCE REPORTING ON CERTAIN FOREIGN ACCOUNTS**

