Unveiling Passthru Payments The Key to FATCA Compliance

For example, the IRS (i) will be required to finalize revised Forms W-8 to comport with FATCA requirements,3 (ii) must release a standard FFI Agreement, (iii) ... Foreign Passthru Payments. Withholding on "foreign passthru payments" (on which the definition of which the Final Regulations continue to ... Each of these calculations is discussed below. B. Passthru Payments – In General. We understand and support the view that FATCA is a reporting ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... To present one very real example, although payments on a swap entered into by a US ... passthru payments the grandfathered obligation date be ... The treatment of foreign passthru payments (FPPs) remains unclear as the IRS has reserved their ... provides greater certainty by explicitly describing payments ... passthru payments made in 2015 and 2016 to persons not participating in FATCA. Furthermore, given general international developments at the ... could be broken if the IRS/Treasury retains the pro-rata approach to passthru payments proposed in IRS Notice 2011-34. In addition to evaluating ... ... passthru payments" but are not otherwise subject to FATCA withholding. ... example, that an FFI is a participating FFI or a registered ...