FATCA Foreign Passthru Payments The Ultimate Guide for Tax Professionals

A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ... q) The term “Nonparticipating Financial Institution” means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. ... 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 ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold ... 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 ... ... FFI that are “attributable to” withholdable payments would be subject to withholding under FATCA (such payments, “foreign passthru payments”). ... definition of foreign pass-through payment in the Proposed Regulations,. Treasury and the IRS have provided some indications of the future definition: (1) No ... the recipient of the payment by eliminating this tax from the definition ... In addition, the passthru payment rules could cover payments on ... “Passthru payments” means any “withholdable payment” and any “foreign passthru payment” and the implementation of such FATCA withholding ...