FATCA's Foreign Passthru Payment Definitions A Key to Compliance

The Foreign Account Tax Compliance Act (FATCA) is a unilateral set of US regulations that applies worldwide for all countries. Payments treated as foreign passthru payments may be treated as ... The definition of a withholdable payment in the Final Regulations generally is. Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... ... definition of the term withholdable payment means any payment ... foreign passthru payment. 2. EXTENSION OF LIMITED BRANCH AND LIMITED ... The threat of withholding on these so-called “foreign passthru payments” has remained conjectural because: (a) the IRS has not yet defined the ... ... payments made to certain foreign entities. ... Accordingly, Treasury and the IRS have not adopted the limited definition of a passthru payment proposed in such ... payments to other foreign entities who have not established their FATCA ... The final regulations reserve on the definition of a foreign passthru payment. Recommends the elimination of foreign passthru payment withholding. ▫ Seeks clarification for the alignment of the Managed Investment Entity definition. The Fatca draft regulations provide that foreign passthru payments are passthru payments that are not withholdable payments. This must mean, therefore, that ... FATCA indicia · A U.S. place of birth · Identification of the account holder as a U.S. citizen or resident · A current U.S. residence or mailing address (including ...