Unlocking the Power of Cross-Border Payments Passthru Payments and FATCA

A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... Extend the date on which “Participating FFIs” must withhold tax on certain “passthru payments” until January 1, 2017; and ... Foreign investment funds, organized ... Defer withholding on foreign passthru payments; Eliminate withholding on certain insurance premiums; Clarify the definition of investment entity ... requirements under the Foreign Account tax Compliance Act (FATCA) and Chapter 3 of the Code. ... passthru payments. Accordingly, under Prop Reg § ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... The Fatca draft regulations provide that foreign passthru payments are passthru payments that are not withholdable payments. This must mean, therefore, that ... 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 ... If a borrower is itself a participating FFI, then there is potentially also "passthru withholding" (from 2017 at the earliest) on payments to a ... (For example, as US Persons,. Foreign Financial Institutions or Non-Financial Foreign. Entities). • Report information to the IRS or local tax authority on all ...