Unlocking the Potential of Passthru Payments through FATCA Optimization

FATCA withholding generally will be required on payments made to FFIs after 2013 and will be required on certain passthru payments made after ... In order for an FFI to be treated as a participating FFI, it must also agree to withhold on passthru payments to recalcitrant account holders ... As the proposed regulations reserve on the definition of “foreign passthru payments,” however, it is not clear whether debt or equity ... Where a foreign bank is unable to report the required information with respect to an account with “US indicia” because, for example ... passthru payments. The IRS ... Searching publicly available information to determine the FATCA status of an entity, for example ... passthru payments' which is included in the ... □ Apply FATCA withholding on withholdable payments and foreign passthru payments to noncompli- ... — How will your distributors be treated under FATCA – for ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... FATCA imposes a 30% U.S. withholding tax on payments to certain foreign entities of U.S. source FDAP1 income and proceeds from the disposition of property that ... 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. ... payments made on or after January 1, 2019;; Defer the effective date for withholding on foreign passthru payments, a “passthru payment ...