FATCA Foreign Passthru Payments A Comprehensive Overview

(See Internal Revenue Code section 7701(a)(31) for the definition of a foreign estate and a foreign trust.), ... The term withholdable payment means:. FATCA has a specific definition for financial institution that may be broader than the definition ... The approach to become a FATCA-compliant FFI depends ... FATCA imposes reporting requirements on FFIs regarding their US account holders, as well as obligations on non-financial foreign entities (NFFEs) regarding ... ... FFI that are “attributable to” withholdable payments would be subject to withholding under FATCA (such payments, “foreign passthru payments”). Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... 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 ... FATCA The term passthru payment means any withholdable payment and any foreign passthru payment. Announcement, until the definition of “foreign pass-thru payment” is defined, this debt ... blockers,” F.A.T.C.A. imposes a withholding tax on foreign pass-thru ... FATCA. Foreign Account Tax Compliance Act. FFI. Foreign Financial Institution. An FFI is defined as any non-U.S. financial institution. A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ...