Demystifying Passthru Payments and FATCA A Guide for Accountants

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implement FATCA, these proposed regulations further extend the time for withholding on foreign passthru payments. Accordingly, under ... ... Passthrough Payment Provisions in Supplemental FATCA Guidance. JUN ... For example, in addition to our concerns regarding passthru payments ... ... passthru payments” (pay- ments attributable to withholdable payments) made ... cluded from the definition of an FFI and are therefore not subject to FATCA. Searching publicly available information to determine the FATCA status of an entity, for example ... passthru payments' which is included in the ... Withholding on foreign passthru payments will be delayed until at least January 1, 2017. FFIs will be required to report annually on the aggregate amounts of ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... A certificate of residence issued by an authorized government body. (for example, ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... Withholdable payments under FATCA are payments of interest, dividends, rents, and certain other specified items of income from US sources. Pass-through payments ... FATCA imposes a 30% withholding tax on “withholdable payments ... payments received by the custodian (“foreign pass-thru payments”)); and ... With respect to other "passthrough" payments—indirect U.S.-source payments to the investor resulting from the Non-U.S. Fund's investment in ...
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