Demystifying FATCA Foreign Passthru Payments A Comprehensive Guide

... definition of foreign pass-through payment in the Proposed Regulations,. Treasury and the IRS have provided some indications of the future definition: (1) No ... In the case of any withholdable payment to a foreign financial institution which does not meet the requirements of subsection (b), the withholding agent with ... An FFI can avoid withholding on pay- ments it receives by entering into an FFI. Agreement with the IRS. A non-financial foreign entity (“NFFE”) ... ... payments made to certain foreign entities. ... Accordingly, Treasury and the IRS have not adopted the limited definition of a passthru payment proposed in such ... What is an FFI? A Foreign Financial Institution (FFI) is defined as an entity that is not resident in the U.S.A. for tax purposes and that ... agent classified under the FATCA rules as a Participating FFI, the definition ... could produce) a foreign passthru payment and cannot produce a withholdable ... Passthru payments are withholdable payments (essentially US source income); and payments that are indirectly attributable to a withholdable ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... obligations that produce or could produce a foreign passthru payment and that cannot produce a withholdable payment, provided that the ...