FATCA Foreign Passthru Payments A Step-by-Step Analysis

... foreign financial institutions (FFIs – see definition of an ... foreign law that would prevent an FFI from reporting the information required under FATCA. What is an FFI? A Foreign Financial Institution (FFI) is defined as an entity that is not resident in the U.S.A. for tax purposes and that ... (7) PASSTHRU PAYMENT- The term passthru payment means any withholdable payment or other payment to the extent attributable to a withholdable payment. (e) ... The new FATCA regulations provide relief for certain entities that may have been inadvertently covered by the definition of an FFI under the ... In the case of any withholdable payment to a foreign financial institution which does not meet the requirements of subsection (b), the withholding agent with ... withholdable payment under FATCA, (for example, interest excluded from gross income under ... definition of a foreign passthru payment. Thus, any ... (See Internal Revenue Code section 7701(a)(31) for the definition of a foreign estate and a foreign trust.), ... The term withholdable payment means:. Non-Participating FFIs are not entitled to interest on any allowed refunds. III. Foreign Financial Institutions. A. FFI Defined - In general, an ... ... definition of an “investment entity,” and the deferral of withholding on foreign passthru payments. These provisions represent a significant ... FATCA. Foreign Account Tax Compliance Act. FFI. Foreign Financial Institution. An FFI is defined as any non-U.S. financial institution.