Unlock the Secrets of Passthru Payments for Enhanced FATCA Reporting

requirements under the Foreign Account tax Compliance Act (FATCA) and Chapter 3 of the Code. ... passthru payments. Accordingly, under Prop Reg § ... 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 ... With respect to other "passthrough" payments—indirect U.S.-source payments to the investor resulting from the Non-U.S. Fund's investment in ... FATCA withholding for U.S. source gross proceeds will begin January 1, 2017. Passthru payments will become subject to FATCA withholding no earlier than January ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... Withholdable payments under FATCA are payments of interest, dividends, rents, and certain other specified items of income from US sources. Pass-through payments ... If these conditions are met, payments to the active NFFE are not subject to the FATCA withholding. ... 331; for more details about 'passthru payments', see Harvey ... ... passthru payments" from January 2017. Now that most European jurisdictions have signed Intergovernmental Agreements (IGAs) with the US (or ... passthru payments made in 2015 and 2016 to persons not participating in FATCA. Furthermore, given general international developments at the ... FATCA. Two model intergovernmental agreements (Model I and Model ... objectives of pass thru payments, but which removes the legal problems for Financial.