Empowering Global Businesses with FATCA Passthru Payment Withholding Strategies

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In the case of any withholdable payment to a foreign financial institution which does not meet the requirements of subsection (b), the withholding agent with ... FATCA withholding for U.S. source gross proceeds will begin January 1, 2017. Passthru payments will become subject to FATCA withholding no earlier than January ... As mentioned above, the proposed regulations eliminate withholding on gross proceeds and defer withholding on passthru payments. Taxpayers ... Eliminate U.S. withholding under FATCA on payments ... Impose passthru payment withholding on payments to recalcitrant account holders, to. Tracing methodology for calculating FATCA withholding on passthru payments and election to avoid passthru payment withholding. In addition ... Under FATCA, US-based funds are treated as US financial institutions (USFIs) and are required to withhold on payments to non-US entity investors who refuse to ... This document contains proposed regulations eliminating withholding on payments of gross proceeds, deferring withholding on foreign passthru payments. Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... ... payments” until two years after final regulations defining foreign passthru payments are published. Foreign financial institutions located in jurisdictions ... Under FATCA, payments of US source income to FFIs are subject to a 30% withholding tax unless the FFI is a participating FFI or otherwise exempt from ...
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