Simplify Passthru Payments with Expert FATCA Compliance Strategies

In addition to withholding tax payable on 'withholdable payments', a withholding tax will also be applied to 'passthru' payments made by an FFI ... For example, Form 5471 is used to report certain direct, ... This is the so-called concept of "passthru payments," defined at Treas. 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 ... requirements under the Foreign Account tax Compliance Act (FATCA) and Chapter 3 of the Code. ... passthru payments. Accordingly, under Prop Reg § ... Payments treated as foreign passthru payments may be treated as Grandfathered up to 6 months after the publication of implementing regulations. H. E. I. B. A. Defer withholding on foreign passthru payments; Eliminate withholding on certain insurance premiums; Clarify the definition of investment entity ... passthru payments made in 2015 and 2016 to persons not participating in FATCA. Furthermore, given general international developments at the ... ... payments would no longer include gross proceeds), (2) deferral of withholding on foreign passthru payments (until 2 years after the definition ... could be broken if the IRS/Treasury retains the pro-rata approach to passthru payments proposed in IRS Notice 2011-34. In addition to evaluating ... Where a foreign bank is unable to report the required information with respect to an account with “US indicia” because, for example ... passthru payments. The IRS ...