Understanding FATCA's Foreign Passthru Payment Definitions

... payment of gross proceeds (definition of FATCA withholdable payments would no longer include gross proceeds), (2) deferral of withholding on ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... The Foreign Account Tax Compliance Act (FATCA) is a law intended to curb the practice of using offshore accounts and financial assets to evade US taxes. ... payments made to certain foreign entities. ... Accordingly, Treasury and the IRS have not adopted the limited definition of a passthru payment proposed in such ... January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ... The 2013 final regulations reserve on the definition of foreign passthru payment ... By identifying a limited FFI on its FATCA registration ... Under FATCA, a passthru payment is defined as “any withholdable payment or other payment to the extent attributable to a withholdable ... The Fatca draft regulations provide that foreign passthru payments are passthru payments that are not withholdable payments. This must mean, therefore, that ... Loans to FFI borrowers: Similarly, Article 4.1 means that UK RFIs will not be required to suffer or administer FATCA withholding on foreign ... – foreign passthru withholding (to be defined in future guidance) on non-US source payments by an FFI that doesn't have the benefit of an ...