Navigating the FATCA Landscape Foreign Passthru Payments

agent classified under the FATCA rules as a Participating FFI, the definition ... could produce) a foreign passthru payment and cannot produce a withholdable ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... obligations that produce or could produce a foreign passthru payment and that cannot produce a withholdable payment, provided that the ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... 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 ... cluded from the definition of an FFI and are therefore not subject to FATCA. ... foreign pass thru payments until January 1, 2017, two years later than in. 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:. What is an FFI? A Foreign Financial Institution (FFI) is defined as an entity that is not resident in the U.S.A. for tax purposes and that ... ... definition of an “investment entity,” and the deferral of withholding on foreign passthru payments. These provisions represent a significant ... Under FATCA, a passthru payment is defined as “any withholdable payment or other payment to the extent attributable to a withholdable ...