FATCA Compliance Unraveling 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 table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made 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 ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... foreign passthru payment and gross proceeds withholding that minimizes burden. ... For purposes of this definition, the term FFI Agreement means where relevant, ... ... foreign passthru payments, eliminate withholding on certain insurance premiums, and clarify the definition of investment entities. The ... 30 Foreign passthrough payments are defined as all other payments made by an FFI other than withholdable payments. Thus, passthrough payments ... The 2013 final regulations reserve on the definition of foreign passthru payment ... By identifying a limited FFI on its FATCA registration ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ...