FATCA Passthru Payment Withholding A Blueprint for Global Tax Compliance

subject to withholding tax of 30% on certain payments received by them. 2. Does FATCA replace the existing U.S. tax withholding and reporting regimes? No ... The Proposed Regulations would defer the withholding requirement on a Foreign Passthrough Payment made to nonparticipating FFIs or recalcitrant ... Similar to the underlying rationale in relation to gross proceeds withholding, our view is that foreign passthru payment withholding is no longer required to ... Participating FFIs are not required to withhold on foreign passthru payments until the later of January 1, 2017 or six months after the date on which ... In the case of an FFI that seeks to avoid withholding tax on a payment ... FATCA withholding on gross proceeds and “passthru” payments remains ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... ... payments (known as “withholdable payments”),. FATCA will ultimately also impose a withholding tax on “foreign passthru payments”, which are ... 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 ... A withholding. Agent is required to withhold 30.0 per cent of any passthru payment made to a non- participating FFI. The underlying purpose of the passthru ... ... payments” until two years after final regulations defining foreign passthru payments are published. Foreign financial institutions located in jurisdictions ...