FATCA Passthru Payment Withholding A Guide to Avoiding Withholding Tax Penalties

Background · Removing FATCA withholding on payments of gross proceeds from the regulations · Deferring withholding on foreign pass-through ... The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. withholding. ▫ Compliance date is January 1, 2019 for withholdable payments that are gross proceeds or “pass-thru” payments. ▫ Reporting Model 1 FFI had ... However, Participating FFIs generally will be required to report (but not withhold on) foreign passthru payments made to non-Participating FFIs. C. Impose passthru payment withholding on payments to other FFIs organized in the FATCA treaty partner or in another jurisdiction with which the United. The. Proposed Regulations would defer the withholding requirement on a Foreign Passthrough Payment made to nonparticipating FFIs or ... 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 ... Similar to the underlying rationale in relation to gross proceeds withholding, our view is that foreign passthru payment withholding is no longer required to ... The current proposed FATCA regulations (“Proposed Regulations”) state that the Internal Revenue Service and the U.S. Treasury have determined, that withholding ...