Mastering the Complexities of FATCA Passthru Payment Withholding for Global Investors

FATCA requires a participating FFI to withhold a 30% tax from any "passthru payment" the FFI makes to a non-participating FFI or a "recalcitrant ... This document contains proposed regulations eliminating withholding on payments of gross proceeds, deferring withholding on foreign passthru payments. (1) Withholding. A participating FFI is required to deduct and withhold tax with respect to payments made to recalcitrant account holders and nonparticipating ... Tracing methodology for calculating FATCA withholding on passthru payments and election to avoid passthru payment withholding. In addition ... 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 ... Participating FFIs must withhold on any passthru payments made to their recalcitrant account holders and to nonparticipating FFIs. Similar to ... Participating FFIs will be required to report Passthru Payments2 beginning January 1, 2015 but will not be required to withhold on Passthru Payments prior to ... In order for an FFI to be treated as a participating FFI, it must also agree to withhold on passthru payments to recalcitrant account holders ... A withholding agent must withhold 30 percent of any withholdable payment made after June 30, 2014, to a foreign financial institution (FFI) (see ... 1 The withholding requirement applies to payments to FFIs and certain nonfinancial foreign entities (NFFEs). FATCA also imposes requirements on ...