Unlock the Power of Passthru Payments for Enhanced FATCA Reporting

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... 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. Withholding on "foreign passthru payments" (on which the definition of which the Final Regulations continue to ... FATCA withholding generally will be required on payments made to FFIs after 2013 and will be required on certain passthru payments made after ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... A certificate of residence issued by an authorized government body. (for example, ... ... passthru payments” (pay- ments attributable to withholdable payments) made ... cluded from the definition of an FFI and are therefore not subject to FATCA. ... payments would no longer include gross proceeds), (2) deferral of withholding on foreign passthru payments (until 2 years after the definition ... withholding on Passthru Payments, eliminate withholding on cer- tain insurance premiums, and clarify the definition of an investment entity, a ... Remove withholding on payments of gross proceeds; · Defer withholding on foreign passthru payments; · Eliminate withholding on certain insurance ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ...
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