Passthru Payments and FATCA A Win-Win for International Trade

The second prong of the definition of pass-thru payments is what is referred ... blockers,” F.A.T.C.A. imposes a withholding tax on foreign pass-thru payments. ... passthru payments for NPFFIs and recalcitrant account holders. Section 1471 ... The ultimate objective of FATCA is to levy taxes upon persons qualified under ... 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 ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... Under the proposed regulations, gross proceeds from the sale or other disposition of an asset will not be subject to FATCA withholding, and passthru payments ... on certain payments (“passthru payments” to account holders and ... FATCA will ultimately also impose a withholding tax on “foreign passthru. Unless future guidance limits the scope of passthru payments, they may capture transactions that are unconnected to U.S.-sourced income. For ... ... payments made on or after January 1, 2019;; Defer the effective date for withholding on foreign passthru payments, a “passthru payment ... The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. 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 ...