FATCA Passthru Payment Withholding A Comprehensive Analysis for Compliance Professionals

The Proposed Regulations would defer the withholding requirement on a Foreign Passthrough Payment made to nonparticipating FFIs or recalcitrant ... FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... ... foreign-to- foreign payments not subject to withholding under Fatca. Similarly, any payment of interest or dividend from Côte d'Azur to the US tax evader. which would thus not be subject to withholding before the foreign passthru payment ... • To properly allocate any FATCA withholding tax ... Passthru payments will become subject to FATCA withholding no earlier than. January 1, 2015. 3. Who is impacted by FATCA? Any entity making a ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... 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 ... That means that. FATCA withholding could apply to a termination payment on an NPC even where ... defining foreign passthru payments are issued. We ... 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 ... (1) Withholding. A participating FFI is required to deduct and withhold tax with respect to payments made to recalcitrant account holders and nonparticipating ...