Demystifying Passthru Payments A Guide to FATCA Compliance for Businesses

... passthru payments" but are not otherwise subject to FATCA withholding. ... example, that an FFI is a participating FFI or a registered ... FATCA withholding generally will be required on payments made to FFIs after 2013 and will be required on certain passthru payments made after ... ... passthru payments for NPFFIs and recalcitrant account holders. Section 1471 ... The ultimate objective of FATCA is to levy taxes upon persons qualified under ... FATCA withholding may be required for "foreign pass-through payments", which are expected to be the subject of future U.S. guidance. 11. What are the ... The agreement will also obligate FFIs to withhold on passthru payments made by the FFI. ▫. Payments to NFFEs will be subject to FATCA. Example. Consider Offshore Fund, Ltd., a ... may still be subject to the FATCA requirements to the extent they receive passthru payments. The second prong of the definition of pass-thru payments is what is referred ... blockers,” F.A.T.C.A. imposes a withholding tax on foreign pass-thru payments. requirements under the Foreign Account tax Compliance Act (FATCA) and Chapter 3 of the Code. ... passthru payments. Accordingly, under Prop Reg § ... Each of these calculations is discussed below. B. Passthru Payments – In General. We understand and support the view that FATCA is a reporting ... 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 ...