Unlocking Global Payments Passthru Payments and FATCA Compliance

... passthru payments" but are not otherwise subject to FATCA withholding. ... example, that an FFI is a participating FFI or a registered ... ... Passthrough Payment Provisions in Supplemental FATCA Guidance. JUN ... For example, in addition to our concerns regarding passthru payments ... Unless future guidance limits the scope of passthru payments, they may capture transactions that are unconnected to U.S.-sourced income. For ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... apply FATCA withholding on passthru payments to others. Under the ... For example, a PFFI that is a bank would be required to withhold ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... ... passthru payments for NPFFIs and recalcitrant account holders. Section 1471 ... The ultimate objective of FATCA is to levy taxes upon persons qualified under ... 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. passthru payments," which are generally foreign source payments made by a ... • For example, under the foreign passthru payment rules, if a ...