Simplify FATCA Compliance Leverage Passthru Payment Systems

Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... implement FATCA, these proposed regulations further extend the time for withholding on foreign passthru payments. Accordingly, under ... The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. In addition, an FFI must withhold. 30% on any pass-through payment it makes to a “recalcitrant account holder”, as well as on payments it makes ... requirements under the Foreign Account tax Compliance Act (FATCA) and Chapter 3 of the Code. ... passthru payments. Accordingly, under Prop Reg § ... passthru payments made in 2015 and 2016 to persons not participating in FATCA. Furthermore, given general international developments at the ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... FATCA withholding generally will be required on payments made to FFIs after 2013 and will be required on certain passthru payments made after ... As the proposed regulations reserve on the definition of “foreign passthru payments,” however, it is not clear whether debt or equity ... FATCA Regs: Investment Entity Definition Clarified & Gross Proceeds Withholding Eliminated · Extend the time for withholding on foreign passthru ...