Passthru Payments Simplified A FATCA Compliance Blueprint for Businesses

would subject passthru payments to withholding only if they are directly traceable to withholdable payments. Treasury felt that a direct tracing approach ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... A certificate of residence issued by an authorized government body. (for example, ... Withholding on foreign passthru payments will be delayed until at least January 1, 2017. FFIs will be required to report annually on the aggregate amounts of ... The Fatca draft regulations provide that foreign passthru payments are passthru payments that are not withholdable payments. This must mean, therefore, that ... For example, if a US person owns an account or a foreign entity holds US securities, payments to those respective accounts will be subject to FATCA (or Form ... Specifically, the amendments will extend: (1) the date for when withholding on gross proceeds and foreign passthru payments will begin; (2) the ... FATCA provisions generally apply to two defined payment types: ( 1) Withholdable Payments and (2) Passthru Payments. However, FATCA withholding is not required ... Thus, a non-participating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ...