FATCA Passthru Payments A Game-Changer for International Businesses (2019)

Pass-through payments under FATCA are certain payments that would originate from a debtor payment, which passes through a foreign financial institution ... Additionally, FATCA imposes a 30% withholding tax on Withholdable Payments and. Passthru Payments made to certain non-U.S. entities that are not FFIs ("Non- ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... Where an FFI chooses not to comply with FATCA, the IRS will impose 30% withholding on payments to FFIs and on behalf of its customers. Entities Required to ... The Proposed Regulations would defer the withholding requirement on a Foreign Passthrough Payment made to nonparticipating FFIs or recalcitrant ... 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 ... Specifically, a withholding agent will be required to begin FATCA withholding on withholdable payments made after June 30, 2014, on payments ... 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 ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... Deduct and withhold a 30% tax on any “passthru payment” to recalcitrant account holders or other FFIs that are not PFFIs, deemed compliant ...