Unlocking Seamless Cross-Border Payments Passthru Payments and FATCA

FATCA withholding generally will be required on payments made to FFIs after 2013 and will be required on certain passthru payments made after ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... Withholdable payments under FATCA are payments of interest, dividends, rents, and certain other specified items of income from US sources. Pass-through payments ... 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. □ Apply FATCA withholding on withholdable payments and foreign passthru payments to noncompli- ... — How will your distributors be treated under FATCA – for ... withholding. ▫ Compliance date is January 1, 2019 for withholdable payments that are gross proceeds or “pass-thru” payments. ▫ Reporting Model 1 FFI had ... 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 ... For example, if a US person owns an account or a foreign entity holds US securities, payments to those respective accounts will be subject to FATCA (or Form ... FATCA. Two model intergovernmental agreements (Model I and Model ... objectives of pass thru payments, but which removes the legal problems for Financial.