FATCA Passthru Payment Withholding A Critical Guide for Global Taxpayers

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 ... 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 the case of any withholdable payment to a foreign financial institution which does not meet the requirements of subsection (b), the withholding agent with ... Participating FFIs will be required to report Passthru Payments2 beginning January 1, 2015 but will not be required to withhold on Passthru Payments prior to ... However, a domestic fund does need to determine if its limited partners are subject to FATCA withholding. ... foreign passthru payment. Participating FFIs will. withholding. ▫ Compliance date is January 1, 2019 for withholdable payments that are gross proceeds or “pass-thru” payments. ▫ Reporting Model 1 FFI had ... ... Tax Compliance Act (FATCA) and chapter 3 of the Internal Revenue Code. ... withholding on foreign passthru payments. These provisions represent ... The Proposed Regulations eliminate withholding on gross proceeds entirely, under the broad statutory grant of authority for the IRS and Treasury ... As mentioned above, the proposed regulations eliminate withholding on gross proceeds and defer withholding on passthru payments. Taxpayers ... Specifically, the proposed regulations eliminate withholding on payments of gross proceeds, defer withholding on foreign passthru payments ...