Decoding Passthru Payments and FATCA A Guide for Financial Institutions

FATCA provisions generally apply to two defined payment types: ( 1) Withholdable Payments and (2) Passthru Payments. However, FATCA withholding is not required ... FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... implement FATCA, these proposed regulations further extend the time for withholding on foreign passthru payments. Accordingly, under ... Treatment of Passthru Payments. The Parties are committed to work together, along with Partner Jurisdictions, to develop a practical and ... For example, article 4.7 of the IGA provides that Luxembourg may allow the use of definitions provided in the relevant U.S. Treasury Regulations instead of ... Under FATCA, payments of US source income to FFIs are subject to a 30% withholding tax unless the FFI is a participating FFI or otherwise exempt from ... For example, the IRS (i) will be required to finalize revised Forms W-8 to comport with FATCA requirements,3 (ii) must release a standard FFI Agreement, (iii) ... Payments treated as foreign passthru payments may be treated as Grandfathered up to 6 months after the publication of implementing regulations. H. E. I. B. A. The agreement will also obligate FFIs to withhold on passthru payments made by the FFI. ▫. Payments to NFFEs will be subject to FATCA. If a borrower is itself a participating FFI, then there is potentially also "passthru withholding" (from 2017 at the earliest) on payments to a ...