Empowering Businesses Passthru Payments and FATCA Compliance

FATCA withholding generally will be required on payments made to FFIs after 2013 and will be required on certain passthru payments made after ... FATCA provisions generally apply to two defined payment types: ( 1) Withholdable Payments and (2) Passthru Payments. However, FATCA withholding is not required ... example, through a nominee) a mandatory distribution or may receive, directly or ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... For example, Form 5471 is used to report certain direct, ... This is the so-called concept of "passthru payments," defined at Treas. FATCA imposes a 30% withholding tax on “withholdable payments ... payments received by the custodian (“foreign pass-thru payments”)); and ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... Subject to a number of exceptions, withholdable payments under FATCA include payments of U.S.-source FDAP income, payments of certain gross ... If a borrower is itself a participating FFI, then there is potentially also "passthru withholding" (from 2017 at the earliest) on payments to a ... Foreign Passthru Payments. Withholding on "foreign passthru payments" (on which the definition of which the Final Regulations continue to ...