Foreign Passthru Payments Understanding FATCA Compliance

□ Apply FATCA withholding on withholdable payments and foreign passthru payments to noncompli- ... definition of a foreign passthru payment. Therefore, further ... ... 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 ... Subject to the exception described in paragraph (a)(4)(i) of this section, a U.S. account is any financial account maintained by an FFI that is held by one or ... FATCA withholding has two major parts: withholdable payments to foreign financial institutions (FFIs) and ... Passthru Payment. The regulations ... 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 ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... 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 threat of withholding on these so-called “foreign passthru payments” has remained conjectural because: (a) the IRS has not yet defined the ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income Payment ... Non-Participating FFIs are not entitled to interest on any allowed refunds. III. Foreign Financial Institutions. A. FFI Defined - In general, an ...