Transforming Passthru Payments with FATCA-Optimized Solutions

In addition, an FFI must withhold. 30% on any pass-through payment it makes to a “recalcitrant account holder”, as well as on payments it makes ... ... Passthrough Payment Provisions in Supplemental FATCA Guidance. JUN ... For example, in addition to our concerns regarding passthru payments ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... Extend the date on which “Participating FFIs” must withhold tax on certain “passthru payments” until January 1, 2017; and ... Foreign investment funds, organized ... Withholdable payments under FATCA are payments of interest, dividends, rents, and certain other specified items of income from US sources. Pass-through payments ... ... passthru payments (“foreign passthru payments”) starting in 2017. The term “withholdable payment” means (1) any payment of U.S. source FDAP ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... withholding on Passthru Payments, eliminate withholding on cer- tain insurance premiums, and clarify the definition of an investment entity, a ... The FATCA regulations also require a participating FFI to withhold 30% of any “passthru payment” to certain recalcitrant account holders or FFIs ... 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 ...