Supercharge Cross-Border Transactions Passthru Payments and FATCA

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. withholding. ▫ Compliance date is January 1, 2019 for withholdable payments that are gross proceeds or “pass-thru” payments. ▫ Reporting Model 1 FFI had ... 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 ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... To present one very real example, although payments on a swap entered into by a US ... passthru payments the grandfathered obligation date be ... Specifically, the amendments will extend: (1) the date for when withholding on gross proceeds and foreign passthru payments will begin; (2) the ... Example. Consider Offshore Fund, Ltd., a ... may still be subject to the FATCA requirements to the extent they receive passthru payments. FATCA imposes a 30% U.S. withholding tax on payments to certain foreign entities of U.S. source FDAP1 income and proceeds from the disposition of property that ... ... passthru payments for NPFFIs and recalcitrant account holders. Section 1471 ... The ultimate objective of FATCA is to levy taxes upon persons qualified under ... FATCA. Two model intergovernmental agreements (Model I and Model ... objectives of pass thru payments, but which removes the legal problems for Financial.