FATCA's Impact on Foreign Passthru Payments A Detailed Analysis

A participating FFI that is prohibited by foreign law from withholding as required under paragraph (b) of this section with respect to an account must close ... FATCA has a specific definition for financial institution that may be broader than the definition ... The approach to become a FATCA-compliant FFI depends ... cluded from the definition of an FFI and are therefore not subject to FATCA. ... foreign pass thru payments until January 1, 2017, two years later than in. The 2013 final regulations reserve on the definition of foreign passthru payment ... By identifying a limited FFI on its FATCA registration ... The purpose of FATCA is to reduce U.S. tax evasion by requiring certain “foreign financial institutions” to report information about U.S. holders of their non- ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... FATCA imposes reporting requirements on FFIs regarding their US account holders, as well as obligations on non-financial foreign entities (NFFEs) regarding ... agent classified under the FATCA rules as a Participating FFI, the definition ... could produce) a foreign passthru payment and cannot produce a withholdable ... (7) PASSTHRU PAYMENT- The term passthru payment means any withholdable payment or other payment to the extent attributable to a withholdable payment. (e) ... q) The term “Nonparticipating Financial Institution” means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not.