FATCA's Foreign Passthru Payments A Comprehensive Explanation

... FFI that are “attributable to” withholdable payments would be subject to withholding under FATCA (such payments, “foreign passthru payments”). ... definition of the term withholdable payment means any payment ... foreign passthru payment. 2. EXTENSION OF LIMITED BRANCH AND LIMITED ... FFIs that do not comply with. FATCA may face 30% withholding on their U.S.-source income. FATCA disclosures generally require an FFI to obtain. implementing FATCA withholding on withholdable payments. ... foreign passthru payment withholding and the definition of investment entity, as. FOREIGN FINANCIAL INSTITUTIONS (FFIs). The tax withholding fully applies to Withholdable Payments in any case, if the. FFI does not enter into the standardized ... (7) PASSTHRU PAYMENT- The term passthru payment means any withholdable payment or other payment to the extent attributable to a withholdable payment. (e) ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... are generally effective for applicable payments made after December 31, 2012, and cast a wide net. The term FFI is defined as any foreign institution that. 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 ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ...