FATCA Passthru Payment Withholding A Must-Read Guide for Non-US Taxpayers and Financial Institutions

Under the tax code, entities that fail to comply with FATCA may be subject to a 30% withholding tax on (i) U.S.-source income, (ii) gross proceeds from the sale ... In this case, the U.S. source is also liable for the withholding tax to be withheld by it. In the case of Passthru Payments, i.e. if a payment is forwarded to a ... FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... Importantly, from 1 January 2017,. Participating FFIs must deduct withholding on payments to non-participating or uncooperative FFIs (“passthru payments”) and ... Tracing methodology for calculating FATCA withholding on passthru payments and election to avoid passthru payment withholding. In addition ... The spectre of withholding on "foreign passthru payments" (non-US source payments derived from US sources) is pushed back to at least 2021. 8488, March 8, 2019, the IRS scheduled an April 10 public hearing on the following proposed regulations eliminating withholding on payments of ... imposes withholding on so-called foreign passthru payments. Withholding does not apply to on payments to a financial institution that ... The Proposed Regulations would defer the withholding requirement on a Foreign Passthrough Payment made to nonparticipating FFIs or recalcitrant ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ...