FATCA Foreign Passthru Payments A Vital Tool for Tax Professionals

The Fatca draft regulations provide that foreign passthru payments are passthru payments that are not withholdable payments. This must mean, therefore, that ... ... FATCA reporting or to FFIs that do not themselves enter into FFI ... In the case of “foreign passthru payments,” the definition of which is ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... Non-Participating FFIs are not entitled to interest on any allowed refunds. III. Foreign Financial Institutions. A. FFI Defined - In general, an ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... FATCA imposes a 30% U.S. withholding tax on payments to certain foreign entities of U.S. source FDAP1 income and proceeds from the disposition of property that ... proposed a definition of “foreign passthru payment”). • Exemption ... The details regarding Participating FFI FATCA compliance are too ... The term "passthru payment" means any withholdable payment or other payment to the extent attributable to a withholdable payment. 1471(e)Affiliated Groups. The term "Nonparticipating Financial Institution" means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. 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 ...