FATCA Reporting 101 A Guide to Foreign Passthru Payments

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– foreign passthru withholding (to be defined in future guidance) on non-US source payments by an FFI that doesn't have the benefit of an ... The new FATCA regulations provide relief for certain entities that may have been inadvertently covered by the definition of an FFI under the ... obligations that produce or could produce a foreign passthru payment and that cannot produce a withholdable payment, provided that the ... FATCA Regs: Investment Entity Definition Clarified & Gross Proceeds Withholding Eliminated · Extend the time for withholding on foreign passthru ... Defer the effective date for withholding on foreign passthru payments, a “passthru payment” having been statutorily defined in the Hire Act as ... Passthru payments means any withholdable payment and any "foreign passthru payment," which is currently not defined. The current proposed FATCA regulations ... The Foreign Account Tax Compliance Act (FATCA) is a law intended to curb the practice of using offshore accounts and financial assets to evade US taxes. The threat of withholding on these so-called “foreign passthru payments” has remained conjectural because: (a) the IRS has not yet defined the ... Loans to FFI borrowers: Similarly, Article 4.1 means that UK RFIs will not be required to suffer or administer FATCA withholding on foreign ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ...
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