Mastering FATCA Compliance Defining Foreign Passthru Payments

The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ... FATCA imposes a 30% U.S. withholding tax on payments to certain foreign entities of U.S. source FDAP1 income and proceeds from the disposition of property that ... Foreign Passthru Payment. INVESTMENT ENTITY CLARIFICATION. The definition of an F.F.I. includes Investment Entities. Under the regulations ... ... payments made to certain foreign entities. ... Accordingly, Treasury and the IRS have not adopted the limited definition of a passthru payment proposed in such ... FATCA imposes reporting requirements on FFIs regarding their US account holders, as well as obligations on non-financial foreign entities (NFFEs) regarding ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... payments to other foreign entities who have not established their FATCA ... The final regulations reserve on the definition of a foreign passthru payment. ... definition of an “investment entity,” and the deferral of withholding on foreign passthru payments. These provisions represent a significant ... proposed a definition of “foreign passthru payment”). • Exemption ... The details regarding Participating FFI FATCA compliance are too ...