Navigating the Complexities of FATCA Foreign Passthru Payments

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Are US branches of foreign entities excepted from the definition of an FFI? No. While there is no such exemption, income that is effectively connected with a US ... Defer withholding on foreign passthru payments; Eliminate withholding on certain insurance premiums; Clarify the definition of investment entity ... Defer the effective date for withholding on foreign passthru payments, a “passthru payment” having been statutorily defined in the Hire Act as ... January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ... The new FATCA regulations provide relief for certain entities that may have been inadvertently covered by the definition of an FFI under the ... Foreign Passthru Payments. Withholding on "foreign passthru payments" (on which the definition of which the Final Regulations continue to ... In the case of any withholdable payment to a foreign financial institution which does not meet the requirements of subsection (b), the withholding agent with ... withholdable payment under FATCA, (for example, interest excluded from gross income under ... definition of a foreign passthru payment. Thus, any ... r). The term “Nonparticipating Financial Institution” means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. “Passthru payments” means any “withholdable payment” and any “foreign passthru payment” and the implementation of such FATCA withholding ...
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