NPFFI definition
Examples of NPFFI in a sentence
In the case of a Trust this means – Non-participating foreign financial institution - An FFI that does not enter into an agreement with the IRS is referred to as a “non-participating foreign financial institution” (NPFFI), and is subject to withholding under FATCA.
The Subscriber agrees to promptly notify the General Partner should the Subscriber's status under FATCA change to that of a NPFFI or a Passive NFFE that fails to certify as to its substantial U.S. owners or that it has no substantial U.S. owners.
The Subscriber represents and warrants that the Subscriber has a status under the Foreign Account Tax Compliance Act, Sections 1471-1474 of the Code, and the regulations, orders, guidelines and agreements promulgated thereunder (collectively, "FA TCA") other than that of a "nonparticipating foreign financial institution" ("NPFFI") or a "Passive nonfinancial foreign entity" ("Passive NFFE") that fails to certify as to its substantial U.S. owners or that it has no substantial U.S. owners.
The Partnership might find itself in a position to close out any NPFFI or Recalcitrant Holder (by for example, forcing it to sell its Limited Partnership Units) in order to comply with its obligations under IGA Model 1 and avoid U.S. withholding tax.