Essential Tips for Handling FATCA Foreign Passthru Payments

Under FATCA, certain FFIs are required to enter into an FFI Agreement with the IRS. The agreement outlines the FFI's legally binding responsibilities which fall ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... Loans to FFI borrowers: Similarly, Article 4.1 means that UK RFIs will not be required to suffer or administer FATCA withholding on foreign ... Defer the effective date for withholding on foreign passthru payments, a “passthru payment” having been statutorily defined in the Hire Act as ... Passthru payments means any withholdable payment and any "foreign passthru payment," which is currently not defined. The current proposed FATCA regulations ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income Payment ... A foreign entity is an FFI if, inter alia, it is an “investment entity” as defined in the Treasury Regulations. There are various circumstances ... The new FATCA regulations provide relief for certain entities that may have been inadvertently covered by the definition of an FFI under the ... The term "Nonparticipating Financial Institution" means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not.