Essential Guide to FATCA Passthru Payment Withholding for Non-US Financial Institutions

Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... After 2015, it may be virtually impossible for foreign financial institutions (FFls) to avoid the reach of the Foreign Account Tax ... which would thus not be subject to withholding before the foreign passthru payment ... • To properly allocate any FATCA withholding tax ... ... payments (known as “withholdable payments”),. FATCA will ultimately also impose a withholding tax on “foreign passthru payments”, which are ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... withholding on certain payments (“Withholdable Payments”). ... Deferral of FATCA Withholding on Foreign Pass-thru Payments: “Foreign Pass-thru. 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 ... Participating FFIs will be required to report Passthru Payments2 beginning January 1, 2015 but will not be required to withhold on Passthru Payments prior to ... In addition, an FFI must withhold 30% on any passthru payment it makes to a recalcitrant account holder, as well as any passthru payment it makes to another FFI ... Pass-through payments under FATCA are certain payments that would originate from a debtor payment, which passes through a foreign financial institution ...