Unveiling FATCA Foreign Passthru Payment Definitions

obligations that produce or could produce a foreign passthru payment and that cannot produce a withholdable payment, provided that the ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... 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 ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... What is a FFI? Foreign Financial Institutions (FFIs) are defined as entities that are not resident in the U.S.A. for tax purposes and that:. Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income Payment ... FATCA indicia · A U.S. place of birth · Identification of the account holder as a U.S. citizen or resident · A current U.S. residence or mailing address (including ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... Foreign Passthru Payments. Withholding on "foreign passthru payments" (on which the definition of which the Final Regulations continue to ...