Essential Guide to FATCA Passthru Payment Withholding for Non-US Entities

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withholding on Passthru Payments, eliminate withholding on cer- tain insurance premiums, and clarify the definition of an investment entity, a ... (1) Withholding. A participating FFI is required to deduct and withhold tax with respect to payments made to recalcitrant account holders and nonparticipating ... The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. As mentioned above, the proposed regulations eliminate withholding on gross proceeds and defer withholding on passthru payments. Taxpayers ... Today the IRS released proposed FATCA regulations which clarify the definition of “Investment Entity,” and eliminate withholding on payments of ... After 2015, it may be virtually impossible for foreign financial institutions (FFls) to avoid the reach of the Foreign Account Tax ... The tax is imposed on the person making the payment to the foreign person, and this payor is often a US financial institution; the payor/withholding agent has ... The Proposed Regulations eliminate withholding on gross proceeds entirely, under the broad statutory grant of authority for the IRS and Treasury ... 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 ... Additionally, FATCA imposes a 30% withholding tax on Withholdable Payments and. Passthru Payments made to certain non-U.S. entities that are not FFIs ("Non- ...
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