FATCA Compliance Clarifying Foreign Passthru Payment Definitions

The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... 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 ... January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... obligations that produce or could produce a foreign passthru payment and that cannot produce a withholdable payment, provided that the ... Non-Participating FFIs are not entitled to interest on any allowed refunds. III. Foreign Financial Institutions. A. FFI Defined - In general, an ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... However, the current US Treasury regulations under FATCA reserve on the definition of a foreign passthru payment, and it is unclear whether ... The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ...