Unleash Cross-Border Commerce Passthru Payments and FATCA Compliance

With respect to other "passthrough" payments—indirect U.S.-source payments to the investor resulting from the Non-U.S. Fund's investment in ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... Subject to a number of exceptions, withholdable payments under FATCA include payments of U.S.-source FDAP income, payments of certain gross ... Foreign Passthru Payments. Withholding on "foreign passthru payments" (on which the definition of which the Final Regulations continue to ... (4) Foreign passthru payments. A participating FFI is not required to deduct ... For example, if a relationship manager is notified that the account ... FATCA provisions generally apply to two defined payment types: • Withholdable payments; and. • Pass-thru payments. However, FATCA withholding is not required ... implement FATCA, these proposed regulations further extend the time for withholding on foreign passthru payments. Accordingly, under ... Remove withholding on payments of gross proceeds; · Defer withholding on foreign passthru payments; · Eliminate withholding on certain insurance ... ... 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 ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ...