FATCA Compliance Understanding Foreign Passthru Payment Definitions

January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold ... What is an FFI? A Foreign Financial Institution (FFI) is defined as an entity that is not resident in the U.S.A. for tax purposes and that ... Recommends the elimination of foreign passthru payment withholding. ▫ Seeks clarification for the alignment of the Managed Investment Entity definition. The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... withholdable payment under FATCA, (for example, interest excluded from gross income under ... definition of a foreign passthru payment. Thus, any ... FATCA The term passthru payment means any withholdable payment and any foreign passthru payment. 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 ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... 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- ...