Mastering Passthru Payments and FATCA Reporting for Global Success

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Specifically, the amendments will extend: (1) the date for when withholding on gross proceeds and foreign passthru payments will begin; (2) the ... The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. ... passthru payments (“foreign passthru payments”) starting in 2017. The term “withholdable payment” means (1) any payment of U.S. source FDAP ... 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 ... The Notice requires an FFI to "publish" its passthru payment percentage by, for example, making the percentage available on the FFI's website ( ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... In addition to withholding tax payable on 'withholdable payments', a withholding tax will also be applied to 'passthru' payments made by an FFI ... ... passthru payments” (pay- ments attributable to withholdable payments) made ... cluded from the definition of an FFI and are therefore not subject to FATCA. To present one very real example, although payments on a swap entered into by a US ... passthru payments the grandfathered obligation date be ... □ Apply FATCA withholding on withholdable payments and foreign passthru payments to noncompli- ... — How will your distributors be treated under FATCA – for ...
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