Passthru Payments and FATCA A Simplified Guide to Complex Regulations

Extend the date on which “Participating FFIs” must withhold tax on certain “passthru payments” until January 1, 2017; and ... Foreign investment funds, organized ... 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 ... Passthru Payments become effective as of January 1, 2015 at the earliest. Page 5. Note: In spite of the partial slowdown of the implementation of the FATCA ... Subject to a number of exceptions, withholdable payments under FATCA include payments of U.S.-source FDAP income, payments of certain gross ... (For example, as US Persons,. Foreign Financial Institutions or Non-Financial Foreign. Entities). • Report information to the IRS or local tax authority on all ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... apply FATCA withholding on passthru payments to others. Under the ... For example, a PFFI that is a bank would be required to withhold ... The Notice requires an FFI to "publish" its passthru payment percentage by, for example, making the percentage available on the FFI's website ( ... Unless future guidance limits the scope of passthru payments, they may capture transactions that are unconnected to U.S.-sourced income. For ...