FATCA Foreign Passthru Payments A Comprehensive Compliance Guide

ee) The term “U.S. Source Withholdable Payment” means any payment of ... alternative approach to achieve the policy objectives of foreign passthru payment and ... agent classified under the FATCA rules as a Participating FFI, the definition ... could produce) a foreign passthru payment and cannot produce a withholdable ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... 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 ... ... definition of foreign pass-through payment in the Proposed Regulations,. Treasury and the IRS have provided some indications of the future definition: (1) No ... Foreign Passthru Payment. INVESTMENT ENTITY CLARIFICATION. The definition of an F.F.I. includes Investment Entities. Under the regulations ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by US taxpayers. be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income Payment ... Subject to the exception described in paragraph (a)(4)(i) of this section, a U.S. account is any financial account maintained by an FFI that is held by one or ...