Master Passthru Payments and FATCA Compliance for Seamless Transactions

... passthru payments” (pay- ments attributable to withholdable payments) made ... cluded from the definition of an FFI and are therefore not subject to FATCA. In addition to withholding tax payable on 'withholdable payments', a withholding tax will also be applied to 'passthru' payments made by an FFI ... In addition, an FFI must withhold 30% on any passthru payment it makes to a recalcitrant account holder, as well as to payments it makes to another FFI unless ... 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 ... FATCA withholding for U.S. source gross proceeds will begin January 1, 2017. Passthru payments will become subject to FATCA withholding no earlier than January ... FATCA Regs: Investment Entity Definition Clarified & Gross Proceeds Withholding Eliminated · Extend the time for withholding on foreign passthru ... Certain “passthru” payments will also be subject to FATCA – a passthru payment generally includes any portion of a payment that is not a ... ... passthru payments" but are not otherwise subject to FATCA withholding. ... example, that an FFI is a participating FFI or a registered ... ... Passthrough Payment Provisions in Supplemental FATCA Guidance. JUN ... For example, in addition to our concerns regarding passthru payments ... ... payments would no longer include gross proceeds), (2) deferral of withholding on foreign passthru payments (until 2 years after the definition ...