Unlocking the Secrets of FATCA Foreign Passthru Payments

Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... 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. withholdable payment under FATCA, (for example, interest excluded from gross income under ... definition of a foreign passthru payment. Thus, any ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... 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 ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... 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. 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 ... Defer the effective date for withholding on foreign passthru payments, a “passthru payment” having been statutorily defined in the Hire Act as ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold ...