FATCA Passthru Payment Withholding A Key to Global Tax Compliance and Avoidance

Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... The Proposed Regulations eliminate withholding on gross proceeds entirely, under the broad statutory grant of authority for the IRS and Treasury ... Tracing methodology for calculating FATCA withholding on passthru payments and election to avoid passthru payment withholding. In addition ... Pass-through payments under FATCA are certain payments that would originate from a debtor payment, which passes through a foreign financial institution ... Based on prior guidance, the foreign passthru payment withholding ... □ Apply FATCA withholding on withholdable payments and foreign passthru payments to ... imposes withholding on so-called foreign passthru payments. Withholding does not apply to on payments to a financial institution that ... ... withholding on foreign-source passthru payments will begin no earlier than 2017. Thus, a non-participating foreign fund could be subject to 30% withholding ... Under prior FATCA regulations, a 30 percent withholding tax was required on payments of gross proceeds to certain foreign entities made after ... withhold on payments made to undocumented payee entities other ... could produce) a foreign passthru payment and cannot produce a withholdable payment. The current proposed FATCA regulations (“Proposed Regulations”) state that the Internal Revenue Service and the U.S. Treasury have determined, that withholding ...