FATCA Passthru Payment Withholding A Guide to Understanding and Compliance for Non-US Entities

with FATCA's reporting, withholding, and account closure requirements. ... foreign pass thru payments until January 1, 2017, two years later than in. (1) Withholding. A participating FFI is required to deduct and withhold tax with respect to payments made to recalcitrant account holders and nonparticipating ... As mentioned above, the proposed regulations eliminate withholding on gross proceeds and defer withholding on passthru payments. Taxpayers ... which would thus not be subject to withholding before the foreign passthru payment ... • To properly allocate any FATCA withholding tax ... Additionally, PFFIs must withhold 30 percent of any passthru payment to a nonparticipating FFI or account holders who refuse to release their. withholding on certain payments (“Withholdable Payments”). ... Deferral of FATCA Withholding on Foreign Pass-thru Payments: “Foreign Pass-thru. ... 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 ... 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 ... subject to withholding tax of 30% on certain payments received by them. 2. Does FATCA replace the existing U.S. tax withholding and reporting regimes? No ... The key problem of passthru payments is how to establish what proportion of any payment originating upstream in the payment chain, is allocable to a given ...