FATCA Foreign Passthru Payments A Comprehensive Guide

Pass-through payments under FATCA are certain payments that would originate from a debtor payment, which passes through a foreign financial institution* (FFI) ... 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 financial institutions (FFIs – see definition of an ... foreign law that would prevent an FFI from reporting the information required under FATCA. Loans to FFI borrowers: Similarly, Article 4.1 means that UK RFIs will not be required to suffer or administer FATCA withholding on foreign ... The term "passthru payment" means any withholdable payment or other payment to the extent attributable to a withholdable payment. 1471(e)Affiliated Groups. FATCA imposes reporting requirements on FFIs regarding their US account holders, as well as obligations on non-financial foreign entities (NFFEs) regarding ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... The term "Nonparticipating Financial Institution" means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. agent classified under the FATCA rules as a Participating FFI, the definition ... could produce) a foreign passthru payment and cannot produce a withholdable ... are generally effective for applicable payments made after December 31, 2012, and cast a wide net. The term FFI is defined as any foreign institution that.