FATCA Passthru Payment Withholding A Critical Guide for Tax Professionals and Global Businesses

of the obligations under US Foreign Account Tax Compliance Act (FATCA) ... impose passthru payment withholding to or close the account of any. ... payments (known as “withholdable payments”),. FATCA will ultimately also impose a withholding tax on “foreign passthru payments”, which are ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... withholding agent makes a payment of U.S. source FDAP income to a participating foreign ... payment of a withholdable payment or a foreign pass thru payment.”. ... F.A.T.C.A. Thus, to prevent the use of “F.A.T.C.A. blockers,” F.A.T.C.A. imposes a withholding tax on foreign pass-thru payments. Although the proposed ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments, and provide that withholding on foreign-source passthru ... That means that. FATCA withholding could apply to a termination payment on an NPC even where ... defining foreign passthru payments are issued. We ... withholding on certain payments (“Withholdable Payments”). ... Deferral of FATCA Withholding on Foreign Pass-thru Payments: “Foreign Pass-thru. 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 ... As mentioned above, the proposed regulations eliminate withholding on gross proceeds and defer withholding on passthru payments. Taxpayers ...