Enhance Transparency Passthru Payments and FATCA Reporting Solutions

Thus, a non-participating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... To present one very real example, although payments on a swap entered into by a US ... passthru payments the grandfathered obligation date be ... (for example) ... ▫ Should generally neither be subject to FATCA withholding on payments they receive, nor required to apply passthru. The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... ... payments would no longer include gross proceeds), (2) deferral of withholding on foreign passthru payments (until 2 years after the definition ... With respect to other "passthrough" payments—indirect U.S.-source payments to the investor resulting from the Non-U.S. Fund's investment in ... ... passthru payments (Treas. Reg. § 1.1471-. 2(b)(2)(i)(B)). 6 See, for example, Article 4.1 of the IGA that the UK has entered into with the US ... ... passthru payments" but are not otherwise subject to FATCA withholding. ... example, that an FFI is a participating FFI or a registered ... Passthru Payments become effective as of January 1, 2015 at the earliest. Page 5. Note: In spite of the partial slowdown of the implementation of the FATCA ...