FATCA Foreign Passthru Payments A Guide to Avoid Costly Penalties

... 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 ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... ... foreign passthru payments, eliminate withholding on certain insurance premiums, and clarify the definition of investment entities. The ... 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 ... 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 ... ... definition of an “investment entity,” and the deferral of withholding on foreign passthru payments. These provisions represent a significant ... Passthru payments means any withholdable payment and any "foreign passthru payment," which is currently not defined. The current proposed FATCA regulations ... implementing FATCA withholding on withholdable payments. ... foreign passthru payment withholding and the definition of investment entity, as. Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... Recommends the elimination of foreign passthru payment withholding. ▫ Seeks clarification for the alignment of the Managed Investment Entity definition.