FATCA Passthru Payment Withholding A Critical Guide for Businesses

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 IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. implementing FATCA withholding on withholdable payments ... foreign passthru payment withholding and that could be more efficiently implemented by. 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 ... This document contains proposed regulations eliminating withholding on payments of gross proceeds, deferring withholding on foreign passthru payments. After 2015, it may be virtually impossible for foreign financial institutions (FFls) to avoid the reach of the Foreign Account Tax ... 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 ... In the case of any withholdable payment to a foreign financial institution which does not meet the requirements of subsection (b), the withholding agent with ... 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 ... The key problem of passthru payments is how to establish what proportion of any payment originating upstream in the payment chain, is allocable to a given ...