Understanding FATCA's Implications for Foreign Passthru Payments

Announcement, until the definition of “foreign pass-thru payment” is defined, this debt ... blockers,” F.A.T.C.A. imposes a withholding tax on foreign pass-thru ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... FATCA imposes reporting requirements on FFIs regarding their US account holders, as well as obligations on non-financial foreign entities (NFFEs) regarding ... FATCA generally defines Foreign Financial Institution (FFI) as follows: ... NFFE is defined as any foreign entity that does not meet the definition of an FFI, and ... are generally effective for applicable payments made after December 31, 2012, and cast a wide net. The term FFI is defined as any foreign institution that. ... FATCA reporting or to FFIs that do not themselves enter into FFI ... In the case of “foreign passthru payments,” the definition of which is ... An FFI can avoid withholding on pay- ments it receives by entering into an FFI. Agreement with the IRS. A non-financial foreign entity (“NFFE”) ... 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 ... FATCA imposes a 30% U.S. withholding tax on payments to certain foreign entities of U.S. source FDAP1 income and proceeds from the disposition of property that ... Foreign Passthru Payment. INVESTMENT ENTITY CLARIFICATION. The definition of an F.F.I. includes Investment Entities. Under the regulations ...