Foreign Passthru Payments Under FATCA A Comprehensive Guide

be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income Payment ... Under FATCA, certain US taxpayers and foreign financial institutions (FFIs) must report information on financial accounts held by US taxpayers ... ... 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 Foreign Account Tax Compliance Act (FATCA) is a unilateral set of US regulations that applies worldwide for all countries. The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold ... 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. ee) The term “U.S. Source Withholdable Payment” means any payment of ... alternative approach to achieve the policy objectives of foreign passthru payment and ... What is a FFI? Foreign Financial Institutions (FFIs) are defined as entities that are not resident in the U.S.A. for tax purposes and that:. 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. FATCA. Foreign Account Tax Compliance Act. FFI. Foreign Financial Institution. An FFI is defined as any non-U.S. financial institution.