Demystifying FATCA Foreign Passthru Payments

What is a FFI? Foreign Financial Institutions (FFIs) are defined as entities that are not resident in the U.S.A. for tax purposes and that:. ... definition of the term withholdable payment means any payment ... foreign passthru payment. 2. EXTENSION OF LIMITED BRANCH AND LIMITED ... FATCA Regs: Investment Entity Definition Clarified & Gross Proceeds Withholding Eliminated · Extend the time for withholding on foreign passthru ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... Non-Participating FFIs are not entitled to interest on any allowed refunds. III. Foreign Financial Institutions. A. FFI Defined - In general, an ... 30 Foreign passthrough payments are defined as all other payments made by an FFI other than withholdable payments. Thus, passthrough 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 ... “Passthru payments” means any “withholdable payment” and any “foreign passthru payment” and the implementation of such FATCA withholding ... The principal targets of FATCA enforcement are “foreign financial institutions” (FFIs). An FFI is a foreign entity that is engaged in a banking, ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold ...