FATCA Reporting Requirements A Focus on Foreign Passthru Payments

The Fatca draft regulations provide that foreign passthru payments are passthru payments that are not withholdable payments. This must mean, therefore, that ... Foreign Passthru Payment. INVESTMENT ENTITY CLARIFICATION. The definition of an F.F.I. includes Investment Entities. Under the regulations ... 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 ... The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ... ... foreign financial institutions (FFIs – see definition of an ... foreign law that would prevent an FFI from reporting the information required under FATCA. (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 ... the recipient of the payment by eliminating this tax from the definition ... In addition, the passthru payment rules could cover payments on ... The principal targets of FATCA enforcement are “foreign financial institutions” (FFIs). An FFI is a foreign entity that is engaged in a banking, ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold ...