Passthru Payments Unveiled A Blueprint for FATCA Compliance in Cross-Border Transactions

... passthru payments for NPFFIs and recalcitrant account holders. Section 1471 ... The ultimate objective of FATCA is to levy taxes upon persons qualified under ... FATCA imposes a 30% withholding tax on “withholdable payments ... payments received by the custodian (“foreign pass-thru payments”)); and ... The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... To present one very real example, although payments on a swap entered into by a US ... passthru payments the grandfathered obligation date be ... As the proposed regulations reserve on the definition of “foreign passthru payments,” however, it is not clear whether debt or equity ... could produce) a foreign passthru payment and cannot produce a withholdable payment. The definition will also include dividend-equivalent payments and any ... ... Passthrough Payment Provisions in Supplemental FATCA Guidance. JUN ... For example, in addition to our concerns regarding passthru payments ... would subject passthru payments to withholding only if they are directly traceable to withholdable payments. Treasury felt that a direct tracing approach ... Subject to a number of exceptions, withholdable payments under FATCA include payments of U.S.-source FDAP income, payments of certain gross ...