Master FATCA Passthru Payment Withholding Essential Strategies

FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... 1 The withholding requirement applies to payments to FFIs and certain nonfinancial foreign entities (NFFEs). FATCA also imposes requirements on ... Withholding may also apply to non-US source payments because of the concept of 'passthru payments' (see below). How to avoid the withholding tax. ... foreign-to- foreign payments not subject to withholding under Fatca. Similarly, any payment of interest or dividend from Côte d'Azur to the US tax evader. The threat of withholding on these so-called “foreign passthru payments” has remained conjectural because: (a) the IRS has not yet defined the ... A withholding agent must withhold 30 percent of any withholdable payment made after June 30, 2014, to a foreign financial institution (FFI) (see ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... C. Impose passthru payment withholding on payments to other FFIs organized in the FATCA treaty partner or in another jurisdiction with which the United. implementing FATCA withholding on withholdable payments ... foreign passthru payment withholding and that could be more efficiently implemented by.