FATCA Compliance for Foreign Entities Passthru Payments

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 ... “Passthru payments” means any “withholdable payment” and any “foreign passthru payment” and the implementation of such FATCA withholding ... A foreign entity is an FFI if, inter alia, it is an “investment entity” as defined in the Treasury Regulations. There are various circumstances ... Additionally, FATCA imposes a 30% withholding tax on Withholdable Payments and. Passthru Payments made to certain non-U.S. entities that are not FFIs ("Non- ... FOREIGN FINANCIAL INSTITUTIONS (FFIs). The tax withholding fully applies to Withholdable Payments in any case, if the. FFI does not enter into the standardized ... Foreign Passthru Payment. INVESTMENT ENTITY CLARIFICATION. The definition of an F.F.I. includes Investment Entities. Under the regulations ... ee) The term “U.S. Source Withholdable Payment” means any payment of ... alternative approach to achieve the policy objectives of foreign passthru payment and ... However, the current US Treasury regulations under FATCA reserve on the definition of a foreign passthru payment, and it is unclear whether ... ... foreign financial institutions (FFIs – see definition of an ... foreign law that would prevent an FFI from reporting the information required under FATCA. 30 Foreign passthrough payments are defined as all other payments made by an FFI other than withholdable payments. Thus, passthrough payments ...