Navigating FATCA Passthru Payment Withholding A Comprehensive Guide for Tax Professionals

In addition, an FFI must withhold 30% on any passthru payment it makes to a recalcitrant account holder, as well as any passthru payment it makes to another FFI ... The proposed rules eliminate withholding on payments of gross proceeds and certain insurance premiums, defer withholding on foreign pass-thru ... Participating FFIs are not required to withhold on foreign passthru payments until the later of January 1, 2017 or six months after the date on which ... The current proposed FATCA regulations (“Proposed Regulations”) state that the Internal Revenue Service and the U.S. Treasury have determined, that withholding ... 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 ... Today the IRS released proposed FATCA regulations which clarify the definition of “Investment Entity,” and eliminate withholding on payments of ... 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 ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... A withholding. Agent is required to withhold 30.0 per cent of any passthru payment made to a non- participating FFI. The underlying purpose of the passthru ... Additionally, PFFIs must withhold 30 percent of any passthru payment to a nonparticipating FFI or account holders who refuse to release their.