FATCA Passthru Payment Withholding A Critical Analysis for Businesses

Withholding on FATCA applies to U.S. withholding agents making U.S. source payments to foreign payees, and also to foreign financial institution ... implementing FATCA withholding on withholdable payments ... foreign passthru payment withholding and that could be more efficiently implemented by. The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. However, Participating FFIs generally will be required to report (but not withhold on) foreign passthru payments made to non-Participating FFIs. If a withholding agent has knowledge of the facts that give rise to a payment but is unable to determine at the time of payment the source of the payment, such ... The elimination of FATCA withholding on gross proceeds and non-cash insurance premiums that are described above also apply to payments made to ... Specifically, the proposed regulations eliminate withholding on payments of gross proceeds, defer withholding on foreign passthru payments ... ... FATCA.60 Withholding by participating FFIs begins on payments made after 31 December 2013.61 Withholding on foreign passthru payments is ... ... withholding on foreign pass thru payments, eliminating withholding on certain insurance premiums, and clarifying the definition of investment 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 ...