Supercharge Passthru Payments Meeting FATCA Regulations

As the proposed regulations reserve on the definition of “foreign passthru payments,” however, it is not clear whether debt or equity ... ... Passthrough Payment Provisions in Supplemental FATCA Guidance. JUN ... For example, in addition to our concerns regarding passthru payments ... Treatment of Passthru Payments. The Parties are committed to work together, along with Partner Jurisdictions, to develop a practical and ... so-called “foreign pass-thru payments” (essentially payments to foreign financial institutions organized as corporations with U.S. investors where the ... 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 ... ... passthru payments (Treas. Reg. § 1.1471-. 2(b)(2)(i)(B)). 6 See, for example, Article 4.1 of the IGA that the UK has entered into with the US ... The Notice requires an FFI to "publish" its passthru payment percentage by, for example, making the percentage available on the FFI's website ( ... The FATCA regulations also require a participating FFI to withhold 30% of any “passthru payment” to certain recalcitrant account holders or FFIs ... ... passthru payments" from January 2017. Now that most European jurisdictions have signed Intergovernmental Agreements (IGAs) with the US (or ... implement FATCA, these proposed regulations further extend the time for withholding on foreign passthru payments. Accordingly, under ...