Unlocking the Potential of Passthru Payments with FATCA Optimization

Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... Withholdable payments under FATCA are payments of interest, dividends, rents, and certain other specified items of income from US sources. Pass-through payments ... Subject to a number of exceptions, withholdable payments under FATCA include payments of U.S.-source FDAP income, payments of certain gross ... 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 ... so-called “foreign pass-thru payments” (essentially payments to foreign financial institutions organized as corporations with U.S. investors where the ... requirements under the Foreign Account tax Compliance Act (FATCA) and Chapter 3 of the Code. ... passthru payments. Accordingly, under Prop Reg § ... 1, 2014 with transitional relief for payments of gross proceeds and passthru payments. 5. November 2013. Page 6. PwC. ➢ The objective of FATCA ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... The Notice requires an FFI to "publish" its passthru payment percentage by, for example, making the percentage available on the FFI's website ( ... 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 ...