Mastering FATCA A Guide to Foreign Passthru Payment Reporting

The Foreign Account Tax Compliance Act (FATCA) is a unilateral set of US regulations that applies worldwide for all countries. Defer withholding on foreign passthru payments; Eliminate withholding on certain insurance premiums; Clarify the definition of investment entity ... Payments treated as foreign passthru payments may be treated as ... The definition of a withholdable payment in the Final Regulations generally is. ... foreign financial institutions (FFIs – see definition of an ... foreign law that would prevent an FFI from reporting the information required under FATCA. Recommends the elimination of foreign passthru payment withholding. ▫ Seeks clarification for the alignment of the Managed Investment Entity definition. FATCA. Foreign Account Tax Compliance Act. FFI. Foreign Financial Institution. An FFI is defined as any non-U.S. financial institution. Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... FATCA has a specific definition for financial institution that may be broader than the definition ... The approach to become a FATCA-compliant FFI depends ... □ Apply FATCA withholding on withholdable payments and foreign passthru payments to noncompli- ... definition of a foreign passthru payment. Therefore, further ... The Fatca draft regulations provide that foreign passthru payments are passthru payments that are not withholdable payments. This must mean, therefore, that ...