Unveiling the Secrets 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 ... FOREIGN FINANCIAL INSTITUTIONS (FFIs). The tax withholding fully applies to Withholdable Payments in any case, if the. FFI does not enter into the standardized ... Under FATCA, a passthru payment is defined as “any withholdable payment or other payment to the extent attributable to a withholdable ... FATCA Regs: Investment Entity Definition Clarified & Gross Proceeds Withholding Eliminated · Extend the time for withholding on foreign passthru ... The tax is imposed on the person making the payment to the foreign person, and this payor is often a US financial institution; the payor/withholding agent has ... FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by US taxpayers. “Passthru payments” means any “withholdable payment” and any “foreign passthru payment” and the implementation of such FATCA withholding ... Passthru payments are withholdable payments (essentially US source income); and payments that are indirectly attributable to a withholdable ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... the recipient of the payment by eliminating this tax from the definition ... In addition, the passthru payment rules could cover payments on ...