Mastering Passthru Payments and FATCA Compliance for Global Growth

FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... example, through a nominee) a mandatory distribution or may receive, directly or ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... apply FATCA withholding on passthru payments to others. Under the ... For example, a PFFI that is a bank would be required to withhold ... passthru payments," which are generally foreign source payments made by a ... • For example, under the foreign passthru payment rules, if a ... Each of these calculations is discussed below. B. Passthru Payments – In General. We understand and support the view that FATCA is a reporting ... If a borrower is itself a participating FFI, then there is potentially also "passthru withholding" (from 2017 at the earliest) on payments to a ... Unless future guidance limits the scope of passthru payments, they may capture transactions that are unconnected to U.S.-sourced income. For ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... Under FATCA, payments of US source income to FFIs are subject to a 30% withholding tax unless the FFI is a participating FFI or otherwise exempt from ... In order for an FFI to be treated as a participating FFI, it must also agree to withhold on passthru payments to recalcitrant account holders ...