Master Passthru Payments A Guide to Navigating FATCA Obligations

Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... A certificate of residence issued by an authorized government body. (for example, ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... on certain payments (“passthru payments” to account holders and ... FATCA will ultimately also impose a withholding tax on “foreign passthru. FATCA provisions generally apply to two defined payment types: • Withholdable payments; and. • Pass-thru payments. However, FATCA withholding is not required ... passthru payments made in 2015 and 2016 to persons not participating in FATCA. Furthermore, given general international developments at the ... Where a foreign bank is unable to report the required information with respect to an account with “US indicia” because, for example ... passthru payments. The IRS ... 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) ... Passthru payments means any withholdable payment and any "foreign passthru payment," which is currently not defined. The current proposed FATCA regulations ... If these conditions are met, payments to the active NFFE are not subject to the FATCA withholding. ... 331; for more details about 'passthru payments', see Harvey ... 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.