FATCA Passthru Payment Withholding A Comprehensive Guide for International Businesses

withholding on Passthru Payments, eliminate withholding on cer- tain insurance premiums, and clarify the definition of an investment entity, a ... Tracing methodology for calculating FATCA withholding on passthru payments and election to avoid passthru payment withholding. In addition ... Under the tax code, entities that fail to comply with FATCA may be subject to a 30% withholding tax on (i) U.S.-source income, (ii) gross proceeds from the sale ... Importantly, from 1 January 2017,. Participating FFIs must deduct withholding on payments to non-participating or uncooperative FFIs (“passthru payments”) and ... The threat of withholding on these so-called “foreign passthru payments” has remained conjectural because: (a) the IRS has not yet defined the ... ... withholding agent with respect to such payment shall deduct and ... (7) PASSTHRU PAYMENT- The term passthru payment means any withholdable payment or other. FATCA requires a participating FFI to withhold a 30% tax from any "passthru payment" the FFI makes to a non-participating FFI or a "recalcitrant ... 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.60 Withholding by participating FFIs begins on payments made after 31 December 2013.61 Withholding on foreign passthru payments is ... FATCA withholding for U.S. source gross proceeds will begin January 1, 2017. Passthru payments will become subject to FATCA withholding no earlier than January ...