FATCA Passthru Payment Withholding A Game-Changer for International Transactions

(1) Withholding. A participating FFI is required to deduct and withhold tax with respect to payments made to recalcitrant account holders and nonparticipating ... However, Participating FFIs generally will be required to report (but not withhold on) foreign passthru payments made to non-Participating FFIs. FATCA creates a new information reporting and withholding regime for payments made to certain foreign ... In addition, an FFI must withhold 30% on any passthru ... 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.”. ... Tax Compliance Act (FATCA) and chapter 3 of the Internal Revenue Code. ... withholding on foreign passthru payments. These provisions represent ... The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. The 30% withholding tax applies to all payments that are 'withholdable payments'. This is a very wide definition and includes a variety of US ... withholding on certain payments (“Withholdable Payments”). ... Deferral of FATCA Withholding on Foreign Pass-thru Payments: “Foreign Pass-thru. FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... which would thus not be subject to withholding before the foreign passthru payment ... • To properly allocate any FATCA withholding tax ...