FATCA provisions apply to “withholdable” payments. “Withholdable payments” are defined as:


  • Any payment of interest (including any portfolio interest and original issue discount), dividends, rents, royalties, salaries, wages, annuities, licensing fees and other FDAP income, gains, and profits, if such payment is from sources within the United States.
  • Any gross proceeds from the sale or disposition of U.S. property of a type that can produce
  • Interest or dividends
  • Interest paid by foreign branches of U.S. banks