Navigating Passthru Payments and FATCA A Guide for Multinational Corporations

could be broken if the IRS/Treasury retains the pro-rata approach to passthru payments proposed in IRS Notice 2011-34. In addition to evaluating ... FATCA provides that certain payments by an FFI to a non-compliant account holder at such FFI that are “attributable to” withholdable payments ... on certain payments (“passthru payments” to account holders and ... FATCA will ultimately also impose a withholding tax on “foreign passthru. FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... ... payments made on or after January 1, 2019;; Defer the effective date for withholding on foreign passthru payments, a “passthru payment ... passthru payments made in 2015 and 2016 to persons not participating in FATCA. Furthermore, given general international developments at the ... To present one very real example, although payments on a swap entered into by a US ... passthru payments the grandfathered obligation date be ... The agreement will also obligate FFIs to withhold on passthru payments made by the FFI. ▫. Payments to NFFEs will be subject to FATCA. The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. withholding on Passthru Payments, eliminate withholding on cer- tain insurance premiums, and clarify the definition of an investment entity, a ...