FATCA Foreign Passthru Payment Definitions A Key to Compliance

Under FATCA, certain FFIs are required to enter into an FFI Agreement with the IRS. The agreement outlines the FFI's legally binding responsibilities which fall ... ... payment of gross proceeds (definition of FATCA withholdable payments would no longer include gross proceeds), (2) deferral of withholding on ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... Payments treated as foreign passthru payments may be treated as ... The definition of a withholdable payment in the Final Regulations generally is. ... foreign financial institutions (FFIs – see definition of an ... foreign law that would prevent an FFI from reporting the information required under FATCA. 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 ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... Foreign Passthru Payment. INVESTMENT ENTITY CLARIFICATION. The definition of an F.F.I. includes Investment Entities. Under the regulations ... FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by US taxpayers. The final regulations, like the proposed regulations, do not define foreign-source passthru payments,11 and provide that withholding on foreign- ...