Unlocking the Complexity of FATCA Foreign Passthru Payments

The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... The Foreign Account Tax Compliance Act (FATCA) is a unilateral set of US regulations that applies worldwide for all countries. implementing FATCA withholding on withholdable payments. ... foreign passthru payment withholding and the definition of investment entity, as. Subject to the exception described in paragraph (a)(4)(i) of this section, a U.S. account is any financial account maintained by an FFI that is held by one or ... ... payments made to certain foreign entities. ... Accordingly, Treasury and the IRS have not adopted the limited definition of a passthru payment proposed in such ... FATCA. Foreign Account Tax Compliance Act. FFI. Foreign Financial Institution. An FFI is defined as any non-U.S. financial institution. Defer withholding on foreign passthru payments; Eliminate withholding on certain insurance premiums; Clarify the definition of investment entity ... FOREIGN FINANCIAL INSTITUTIONS (FFIs). The tax withholding fully applies to Withholdable Payments in any case, if the. FFI does not enter into the standardized ... The term "passthru payment" means any withholdable payment or other payment to the extent attributable to a withholdable payment. 1471(e)Affiliated Groups. The IRS has reserved the possibility of introducing withholding on “foreign passthru payments”. ... Means the Foreign Account Tax ...