Unlocking the Value of Passthru Payments A Blueprint for FATCA Compliance

For example, if an entity is classified as an Exempt Beneficial ... passthru payments. This withholding will now not be required before ... withholding. ▫ Compliance date is January 1, 2019 for withholdable payments that are gross proceeds or “pass-thru” payments. ▫ Reporting Model 1 FFI had ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... A certificate of residence issued by an authorized government body. (for example, ... FATCA withholding may be required for "foreign pass-through payments", which are expected to be the subject of future U.S. guidance. 11. What are the ... For example, Form 5471 is used to report certain direct, ... This is the so-called concept of "passthru payments," defined at Treas. The Notice requires an FFI to "publish" its passthru payment percentage by, for example, making the percentage available on the FFI's website ( ... FATCA. Two model intergovernmental agreements (Model I and Model ... objectives of pass thru payments, but which removes the legal problems for Financial. 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 ... ... passthru payments (Treas. Reg. § 1.1471-. 2(b)(2)(i)(B)). 6 See, for example, Article 4.1 of the IGA that the UK has entered into with the US ... 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.