Empowering Tax Professionals with FATCA Foreign Passthru Payment Knowledge

The principal targets of FATCA enforcement are “foreign financial institutions” (FFIs). An FFI is a foreign entity that is engaged in a banking, ... FOREIGN FINANCIAL INSTITUTIONS (FFIs). The tax withholding fully applies to Withholdable Payments in any case, if the. FFI does not enter into the standardized ... withholdable payment under FATCA, (for example, interest excluded from gross income under ... definition of a foreign passthru payment. Thus, any ... – 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 ... agent classified under the FATCA rules as a Participating FFI, the definition ... could produce) a foreign passthru payment and cannot produce a withholdable ... (7) PASSTHRU PAYMENT- The term passthru payment means any withholdable payment or other payment to the extent attributable to a withholdable payment. (e) ... 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 ... □ Apply FATCA withholding on withholdable payments and foreign passthru payments to noncompli- ... definition of a foreign passthru payment. Therefore, further ... January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ... ... definition of an “investment entity,” and the deferral of withholding on foreign passthru payments. These provisions represent a significant ...