Navigating the Intricacies of Passthru Payments and FATCA A Comprehensive Guide

1, 2014 with transitional relief for payments of gross proceeds and passthru payments. 5. November 2013. Page 6. PwC. ➢ The objective of FATCA ... FATCA provisions generally apply to two defined payment types: • Withholdable payments; and. • Pass-thru payments. However, FATCA withholding is not required ... Certain “passthru” payments will also be subject to FATCA – a passthru payment generally includes any portion of a payment that is not a ... For example, article 4.7 of the IGA provides that Luxembourg may allow the use of definitions provided in the relevant U.S. Treasury Regulations instead of ... Extend the date on which “Participating FFIs” must withhold tax on certain “passthru payments” until January 1, 2017; and ... Foreign investment funds, organized ... apply FATCA withholding on passthru payments to others. Under the ... For example, a PFFI that is a bank would be required to withhold ... Treatment of Passthru Payments. The Parties are committed to work together, along with Partner Jurisdictions, to develop a practical and ... could produce) a foreign passthru payment and cannot produce a withholdable payment. The definition will also include dividend-equivalent payments and any ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... ... passthru payments" from January 2017. Now that most European jurisdictions have signed Intergovernmental Agreements (IGAs) with the US (or ...