The Ultimate Guide to Passthru Payments and FATCA Compliance

For example, article 4.7 of the IGA provides that Luxembourg may allow the use of definitions provided in the relevant U.S. Treasury Regulations instead of ... Withholding on foreign passthru payments will be delayed until at least January 1, 2017. FFIs will be required to report annually on the aggregate amounts of ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... FATCA withholding generally will be required on payments made to FFIs after 2013 and will be required on certain passthru payments made after ... Passthru Payments become effective as of January 1, 2015 at the earliest. Page 5. Note: In spite of the partial slowdown of the implementation of the FATCA ... Extend the date on which “Participating FFIs” must withhold tax on certain “passthru payments” until January 1, 2017; and ... Foreign investment funds, organized ... For example, if an entity is classified as an Exempt Beneficial ... passthru payments. This withholding will now not be required before ... ... 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 ... apply FATCA withholding on passthru payments to others. Under the ... For example, a PFFI that is a bank would be required to withhold ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... A certificate of residence issued by an authorized government body. (for example, ...