Uncover the Secrets of Passthru Payments for FATCA Compliance

(For example, as US Persons,. Foreign Financial Institutions or Non-Financial Foreign. Entities). • Report information to the IRS or local tax authority on all ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... Example. Consider Offshore Fund, Ltd., a ... may still be subject to the FATCA requirements to the extent they receive passthru payments. The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... The second prong of the definition of pass-thru payments is what is referred ... blockers,” F.A.T.C.A. imposes a withholding tax on foreign pass-thru payments. would subject passthru payments to withholding only if they are directly traceable to withholdable payments. Treasury felt that a direct tracing approach ... Treatment of Passthru Payments. The Parties are committed to work together, along with Partner Jurisdictions, to develop a practical and ... could produce) a foreign passthru payment and cannot produce a withholdable payment. The definition will also include dividend-equivalent payments and any ... 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. Each of these calculations is discussed below. B. Passthru Payments – In General. We understand and support the view that FATCA is a reporting ...