Simplifying International Payments Passthru Payments and FATCA

If a borrower is itself a participating FFI, then there is potentially also "passthru withholding" (from 2017 at the earliest) on payments to a ... 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. In addition, an FFI must withhold 30% on any passthru payment it makes to a recalcitrant account holder, as well as to payments it makes to another FFI unless. FATCA Regs: Investment Entity Definition Clarified & Gross Proceeds Withholding Eliminated · Extend the time for withholding on foreign passthru ... FATCA imposes a 30% withholding tax on “withholdable payments ... payments received by the custodian (“foreign pass-thru payments”)); and ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... FATCA withholding may be required for "foreign pass-through payments", which are expected to be the subject of future U.S. guidance. 11. What are the ... requirements under the Foreign Account tax Compliance Act (FATCA) and Chapter 3 of the Code. ... passthru payments. Accordingly, under Prop Reg § ... FATCA provides that certain payments by an FFI to a non-compliant account holder at such FFI that are “attributable to” withholdable payments ... ... passthru payments" but are not otherwise subject to FATCA withholding. ... example, that an FFI is a participating FFI or a registered ...