Unlocking FATCA Foreign Passthru Payments Definitions and Implications

be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income Payment ... Under FATCA, certain types of financial institutions are required to register with the IRS or face a very significant penalty of 30 per cent withholding tax. ... definition of the term withholdable payment means any payment ... foreign passthru payment. 2. EXTENSION OF LIMITED BRANCH AND LIMITED ... Non-Participating FFIs are not entitled to interest on any allowed refunds. III. Foreign Financial Institutions. A. FFI Defined - In general, an ... (7) PASSTHRU PAYMENT- The term passthru payment means any withholdable payment or other payment to the extent attributable to a withholdable payment. (e) ... Defer the effective date for withholding on foreign passthru payments, a “passthru payment” having been statutorily defined in the Hire Act as ... 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 payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... payments to other foreign entities who have not established their FATCA ... The final regulations reserve on the definition of a foreign passthru payment. The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ...