Navigating FATCA's Complexities Foreign Passthru Payment Definitions

Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... r). The term “Nonparticipating Financial Institution” means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. The principal targets of FATCA enforcement are “foreign financial institutions” (FFIs). An FFI is a foreign entity that is engaged in a banking, ... FOREIGN FINANCIAL INSTITUTIONS (FFIs). The tax withholding fully applies to Withholdable Payments in any case, if the. FFI does not enter into the standardized ... 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:. Under FATCA, a passthru payment is defined as “any withholdable payment or other payment to the extent attributable to a withholdable ... ... FFI that are “attributable to” withholdable payments would be subject to withholding under FATCA (such payments, “foreign passthru payments”). A foreign entity is an FFI if, inter alia, it is an “investment entity” as defined in the Treasury Regulations. There are various circumstances ... FATCA has a specific definition for financial institution that may be broader than the definition ... The approach to become a FATCA-compliant FFI depends ... The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ...