Mastering FATCA's Foreign Passthru Payment Rules with Ease

The threat of withholding on these so-called “foreign passthru payments” has remained conjectural because: (a) the IRS has not yet defined the ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold ... 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 ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... The Foreign Account Tax Compliance Act (FATCA) is a unilateral set of US regulations that applies worldwide for all countries. 30 Foreign passthrough payments are defined as all other payments made by an FFI other than withholdable payments. Thus, passthrough payments ... The new rules require 1) foreign financial institutions (FFI's) to provide the. Internal Revenue Service (IRS) with information on certain U.S. persons invested ... – foreign passthru withholding (to be defined in future guidance) on non-US source payments by an FFI that doesn't have the benefit of an ... ... definition of foreign pass-through payment in the Proposed Regulations,. Treasury and the IRS have provided some indications of the future definition: (1) No ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ...