FATCA Compliance Foreign Passthru Payment Definitions Simplified

FATCA withholding has two major parts: withholdable payments to foreign financial institutions (FFIs) and ... Passthru Payment. The regulations ... A foreign entity is an FFI if, inter alia, it is an “investment entity” as defined in the Treasury Regulations. There are various circumstances ... Foreign Passthru Payments. Withholding on "foreign passthru payments" (on which the definition of which the Final Regulations continue to ... ... payments made to certain foreign entities. ... Accordingly, Treasury and the IRS have not adopted the limited definition of a passthru payment proposed in such ... withholdable payment under FATCA, (for example, interest excluded from gross income under ... definition of a foreign passthru payment. Thus, any ... cluded from the definition of an FFI and are therefore not subject to FATCA. ... foreign pass thru payments until January 1, 2017, two years later than in. The Foreign Account Tax Compliance Act (FATCA) is a unilateral set of US regulations that applies worldwide for all countries. ... FATCA reporting or to FFIs that do not themselves enter into FFI ... In the case of “foreign passthru payments,” the definition of which is ... Passthru payments are withholdable payments (essentially US source income); and payments that are indirectly attributable to a withholdable ... ... definition of foreign pass-through payment in the Proposed Regulations,. Treasury and the IRS have provided some indications of the future definition: (1) No ...