Simplify International Payments Passthru Payments and FATCA

(for example) ... ▫ Should generally neither be subject to FATCA withholding on payments they receive, nor required to apply passthru. Example. Consider Offshore Fund, Ltd., a ... may still be subject to the FATCA requirements to the extent they receive passthru payments. If a borrower is itself a participating FFI, then there is potentially also "passthru withholding" (from 2017 at the earliest) on payments to a ... Extend the date on which “Participating FFIs” must withhold tax on certain “passthru payments” until January 1, 2017; and ... Foreign investment funds, organized ... In addition to withholding tax payable on 'withholdable payments', a withholding tax will also be applied to 'passthru' payments made by an FFI ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... A certificate of residence issued by an authorized government body. (for example, ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... 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 ... Subject to a number of exceptions, withholdable payments under FATCA include payments of U.S.-source FDAP income, payments of certain gross ... FATCA withholding for U.S. source gross proceeds will begin January 1, 2017. Passthru payments will become subject to FATCA withholding no earlier than January ...