Navigating FATCA Compliance Passthru Payments as a Solution

FATCA provides that certain payments by an FFI to a non-compliant account holder at such FFI that are “attributable to” withholdable payments ... Passthru payments means any withholdable payment and any "foreign passthru payment," which is currently not defined. The current proposed FATCA regulations ... The agreement will also obligate FFIs to withhold on passthru payments made by the FFI. ▫. Payments to NFFEs will be subject to FATCA. □ Apply FATCA withholding on withholdable payments and foreign passthru payments to noncompli- ... — How will your distributors be treated under FATCA – for ... Example. Consider Offshore Fund, Ltd., a ... may still be subject to the FATCA requirements to the extent they receive passthru payments. FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... For example, if an entity is classified as an Exempt Beneficial ... passthru payments. This withholding will now not be required before ... For example, Form 5471 is used to report certain direct, ... This is the so-called concept of "passthru payments," defined at Treas. Treatment of Passthru Payments. The Parties are committed to work together, along with Partner Jurisdictions, to develop a practical and ... For example, if a US person owns an account or a foreign entity holds US securities, payments to those respective accounts will be subject to FATCA (or Form ...