Understanding FATCA A Guide to Foreign Passthru Payment Definitions

FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... The Fatca draft regulations provide that foreign passthru payments are passthru payments that are not withholdable payments. This must mean, therefore, that ... Payments treated as foreign passthru payments may be treated as ... The definition of a withholdable payment in the Final Regulations generally is. q) The term “Nonparticipating Financial Institution” means a nonparticipating. FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not. An FFI is defined as any financial institution that is a foreign entity, other than a financial institution organized under the laws of a possession of the ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... 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 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 ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... Defer the effective date for withholding on foreign passthru payments, a “passthru payment” having been statutorily defined in the Hire Act as ...