FATCA Passthru Payment Withholding A Critical Guide for Tax and Financial Professionals

... withholding tax on “withholdable payments” to a Foreign ... passthru payments to withholding only if they are directly traceable to withholdable payments. Specifically, the proposed regulations eliminate withholding on payments of gross proceeds, defer withholding on foreign passthru payments ... 1 The withholding requirement applies to payments to FFIs and certain nonfinancial foreign entities (NFFEs). FATCA also imposes requirements on ... PFFI. Participating Foreign Financial Institution as defined in the US FATCA regulations ... withholding prior to making a payment);. •. Interests not issued 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 ... In this case, the U.S. source is also liable for the withholding tax to be withheld by it. In the case of Passthru Payments, i.e. if a payment is forwarded to a ... Participating FFIs are not required to withhold on foreign passthru payments until the later of January 1, 2017 or six months after the date on which ... with FATCA's reporting, withholding, and account closure requirements. ... foreign pass thru payments until January 1, 2017, two years later than in. Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving money ... Similar to the underlying rationale in relation to gross proceeds withholding, our view is that foreign passthru payment withholding is no longer required to ...