FATCA Foreign Passthru Payment Definitions A Comprehensive Analysis

FATCA generally defines Foreign Financial Institution (FFI) as follows: ... NFFE is defined as any foreign entity that does not meet the definition of an FFI, and ... A foreign entity is an FFI if, inter alia, it is an “investment entity” as defined in the Treasury Regulations. There are various circumstances ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... The purpose of FATCA is to reduce U.S. tax evasion by requiring certain “foreign financial institutions” to report information about U.S. holders of their non- ... ... 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 ... proposed a definition of “foreign passthru payment”). • Exemption ... The details regarding Participating FFI FATCA compliance are too ... Loans to FFI borrowers: Similarly, Article 4.1 means that UK RFIs will not be required to suffer or administer FATCA withholding on foreign ... FFIs that do not comply with. FATCA may face 30% withholding on their U.S.-source income. FATCA disclosures generally require an FFI to obtain. The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ...