Navigating the Complexities of Passthru Payments with FATCA Compliance

The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... For example, if an entity is classified as an Exempt Beneficial ... passthru payments. This withholding will now not be required before ... apply FATCA withholding on passthru payments to others. Under the ... For example, a PFFI that is a bank would be required to withhold ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... For example, the IRS (i) will be required to finalize revised Forms W-8 to comport with FATCA requirements,3 (ii) must release a standard FFI Agreement, (iii) ... FATCA withholding generally will be required on payments made to FFIs after 2013 and will be required on certain passthru payments made after ... If a borrower is itself a participating FFI, then there is potentially also "passthru withholding" (from 2017 at the earliest) on payments to a ... To present one very real example, although payments on a swap entered into by a US ... passthru payments the grandfathered obligation date be ... 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 ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... A certificate of residence issued by an authorized government body. (for example, ...