Mastering FATCA Passthru Payment Withholding A Comprehensive Guide for Global Tax Compliance

If a withholding agent has knowledge of the facts that give rise to a payment but is unable to determine at the time of payment the source of the payment, such ... Participating FFIs must withhold on any passthru payments made to their recalcitrant account holders and to nonparticipating FFIs. Similar to ... Today the IRS released proposed FATCA regulations which clarify the definition of “Investment Entity,” and eliminate withholding on payments of ... Pass-through payments under FATCA are certain payments that would originate from a debtor payment, which passes through a foreign financial institution ... PFFI. Participating Foreign Financial Institution as defined in the US FATCA regulations ... withholding prior to making a payment);. •. Interests not issued by ... Under FATCA, payments of US source income to FFIs are subject to a 30% withholding tax unless the FFI is a participating FFI or otherwise exempt from ... The Proposed Regulations would defer the withholding requirement on a Foreign Passthrough Payment made to nonparticipating FFIs or recalcitrant ... Similar to the underlying rationale in relation to gross proceeds withholding, our view is that foreign passthru payment withholding is no longer required to ... 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) ...