Demystifying FATCA A Comprehensive Guide to Foreign Passthru Payments

– foreign passthru withholding (to be defined in future guidance) on non-US source payments by an FFI that doesn't have the benefit of an ... ... define the term "foreign passthru payment" are filed with the Federal Register. Second, instruments that produce withholdable payments ... The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ... Passthru payments are withholdable payments (essentially US source income); and payments that are indirectly attributable to a withholdable ... However, the current US Treasury regulations under FATCA reserve on the definition of a foreign passthru payment, and it is unclear whether ... Additionally, FATCA imposes a 30% withholding tax on Withholdable Payments and. Passthru Payments made to certain non-U.S. entities that are not FFIs ("Non- ... q) The term “Nonparticipating Financial Institution” means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. The 2013 final regulations reserve on the definition of foreign passthru payment ... By identifying a limited FFI on its FATCA registration ... 30 Foreign passthrough payments are defined as all other payments made by an FFI other than withholdable payments. Thus, passthrough payments ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ...