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Stephen Fiamma, US Tax Partner, London Office

Presentation to ICMA Members. Stephen Fiamma, US Tax Partner, London Office. September 2012. FATCA and capital markets: Payment chain with U.S. Issuer and multiple FFI intermediaries. PFFI. $200. Clearing System 1 PFFI 50% PTP. Non-PFFI. $140 ($60). $600. $200. PFFI (broker). $200.

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Stephen Fiamma, US Tax Partner, London Office

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  1. Presentation to ICMA Members Stephen Fiamma, US Tax Partner, London Office September 2012

  2. FATCA and capital markets: Payment chain with U.S. Issuer and multiple FFI intermediaries PFFI $200 Clearing System 1 PFFI 50% PTP Non-PFFI $140 ($60) $600 $200 PFFI (broker) $200 Compliant individual $1,200 U.S. Corp Paying Agent PFFI 20% PTP E.g. interest PFFI $140 $420 ($180) Clearing System 2 Non-PFFI No PTP Non-PFFI $140 $140 PFFI (broker) $140 Compliant individual PFFI participating foreign financial institution Non-PFFI non-participating foreign financial institution PTP passthru payment percentage intermediary (e.g. paying agent, clearing system, agent bank) beneficial owner ($0) withheld amount

  3. FATCA and capital markets: Passthru payment chain with FFI Issuer PFFI $200 Clearing System 1 PFFI 50% PTP Non-PFFI $194 ($6) $600 $200 PFFI (broker) $200 Compliant individual $1,200 PFFI 10% PTP Paying Agent PFFI 20% PTP E.g. interest PFFI $194 $582 ($18) Clearing System 2 Non-PFFI No PTP Non-PFFI $194 $194 PFFI (broker) $194 Compliant individual PFFI participating foreign financial institution Non-PFFI non-participating foreign financial institution PTP passthru payment percentage intermediary (e.g. paying agent, clearing system, agent bank) beneficial owner ($0) withheld amount

  4. FATCA and the secondary markets: Payment chain with FFI Purchaser Non-PFFI (broker) $360 PFFI (seller) $360 ($40) PFFI (clearing bank) $400 $800 Compliant individual (seller) PFFI (account bank) PFFI (broker) $400 PFFI 10% PTP (purchaser acting as own clearing bank) Clearing System PFFI 50% PTP $1,200 $360 ($40) Non-PFFI (seller acting as own clearing bank) PFFI participating foreign financial institution Non-PFFI non-participating foreign financial institution PTP passthru payment percentage intermediary (e.g. paying agent, clearing system, agent bank) beneficial owner ($0) withheld amount

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