FATCA Foreign Passthru Payment Definitions A Detailed Explanation

... FFI that are “attributable to” withholdable payments would be subject to withholding under FATCA (such payments, “foreign passthru payments”). q) The term “Nonparticipating Financial Institution” means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. Under FATCA, certain US taxpayers and foreign financial institutions (FFIs) must report information on financial accounts held by US taxpayers ... 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- ... ... defined in an applicable Model 1 intergovernmental agreement (IGA). The Notice states that an FFI in an eligible Model 1 IGA jurisdiction that complies with ... FATCA imposes reporting requirements on FFIs regarding their US account holders, as well as obligations on non-financial foreign entities (NFFEs) regarding ... obligations that produce or could produce a foreign passthru payment and that cannot produce a withholdable payment, provided that the ... The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ... FATCA imposes a 30% U.S. withholding tax on payments to certain foreign entities of U.S. source FDAP1 income and proceeds from the disposition of property that ... 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 ...