Demystifying FATCA's Foreign Passthru Payment Definitions

FFIs that do not comply with. FATCA may face 30% withholding on their U.S.-source income. FATCA disclosures generally require an FFI to obtain. Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ... Are US branches of foreign entities excepted from the definition of an FFI? No. While there is no such exemption, income that is effectively connected with a US ... payments to other foreign entities who have not established their FATCA ... The final regulations reserve on the definition of a foreign passthru payment. The term "Nonparticipating Financial Institution" means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold ... The new FATCA regulations provide relief for certain entities that may have been inadvertently covered by the definition of an FFI under the ...