The Essential Guide to FATCA Foreign Passthru Payment Reporting

Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... The term "passthru payment" means any withholdable payment or other payment to the extent attributable to a withholdable payment. 1471(e)Affiliated Groups. payments to other foreign entities who have not established their FATCA ... The final regulations reserve on the definition of a foreign passthru payment. Under FATCA, a passthru payment is defined as “any withholdable payment or other payment to the extent attributable to a withholdable ... ... payments made to certain foreign entities. ... Accordingly, Treasury and the IRS have not adopted the limited definition of a passthru payment proposed in such ... Passthru payments means any withholdable payment and any "foreign passthru payment," which is currently not defined. The current proposed FATCA regulations ... r). The term “Nonparticipating Financial Institution” means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. 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.