Mastering the Art of FATCA Passthru Payment Withholding for Global Compliance

The spectre of withholding on "foreign passthru payments" (non-US source payments derived from US sources) is pushed back to at least 2021. Under prior FATCA regulations, a 30 percent withholding tax was required on payments of gross proceeds to certain foreign entities made after ... ... withholding on foreign-source passthru payments will begin no earlier than 2017. Thus, a non-participating foreign fund could be subject to 30% withholding ... 8488, March 8, 2019, the IRS scheduled an April 10 public hearing on the following proposed regulations eliminating withholding on payments of ... The current proposed FATCA regulations (“Proposed Regulations”) state that the Internal Revenue Service and the U.S. Treasury have determined, that withholding ... ... withholding on foreign pass thru payments, eliminating withholding on certain insurance premiums, and clarifying the definition of investment withholding on certain payments (“Withholdable Payments”). ... Deferral of FATCA Withholding on Foreign Pass-thru Payments: “Foreign Pass-thru. Importantly, from 1 January 2017,. Participating FFIs must deduct withholding on payments to non-participating or uncooperative FFIs (“passthru payments”) and ... ... withholding tax on “withholdable payments” to a Foreign ... passthru payments to withholding only if they are directly traceable to withholdable payments. The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments.