Empowering Tax Professionals Mastering FATCA Passthru Payment Withholding

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Withholding may also apply to non-US source payments because of the concept of 'passthru payments' (see below). How to avoid the withholding tax. ... FATCA.60 Withholding by participating FFIs begins on payments made after 31 December 2013.61 Withholding on foreign passthru payments is ... FATCA provisions generally apply to two defined payment types: • Withholdable payments; and. • Pass-thru payments. However, FATCA withholding is not required ... 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 ... ... payments (known as “withholdable payments”),. FATCA will ultimately also impose a withholding tax on “foreign passthru payments”, which are ... Tracing methodology for calculating FATCA withholding on passthru payments and election to avoid passthru payment withholding. In addition ... In order for an FFI to be treated as a participating FFI, it must also agree to withhold on passthru payments to recalcitrant account holders ... FATCA creates a new information reporting and withholding regime for payments made to certain foreign ... In addition, an FFI must withhold 30% on any passthru ... ... withholding tax on “withholdable payments” to a Foreign ... passthru payments to withholding only if they are directly traceable to withholdable payments. (1) Withholding. A participating FFI is required to deduct and withhold tax with respect to payments made to recalcitrant account holders and nonparticipating ...
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