Passthru Payments and FATCA A Comprehensive Resource for Seamless Compliance

... passthru payments (“foreign passthru payments”) starting in 2017. The term “withholdable payment” means (1) any payment of U.S. source FDAP ... FATCA provides that certain payments by an FFI to a non-compliant account holder at such FFI that are “attributable to” withholdable payments ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... Example. Consider Offshore Fund, Ltd., a ... may still be subject to the FATCA requirements to the extent they receive passthru payments. FATCA. Two model intergovernmental agreements (Model I and Model ... objectives of pass thru payments, but which removes the legal problems for Financial. To present one very real example, although payments on a swap entered into by a US ... passthru payments the grandfathered obligation date be ... FATCA imposes a 30% withholding tax on “withholdable payments ... payments received by the custodian (“foreign pass-thru payments”)); and ... Extend the date on which “Participating FFIs” must withhold tax on certain “passthru payments” until January 1, 2017; and ... Foreign investment funds, organized ... implement FATCA, these proposed regulations further extend the time for withholding on foreign passthru payments. Accordingly, under ... For example, if an entity is classified as an Exempt Beneficial ... passthru payments. This withholding will now not be required before ...