Navigating the FATCA Passthru Payment Withholding Landscape for Multinational Corporations

Participating FFIs must withhold on any passthru payments made to their recalcitrant account holders and to nonparticipating FFIs. Similar to ... Under prior FATCA regulations, a 30 percent withholding tax was required on payments of gross proceeds to certain foreign entities made after ... 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 ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving money ... 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 ... The 30% withholding tax applies to all payments that are 'withholdable payments'. This is a very wide definition and includes a variety of US ... 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 ... The current proposed FATCA regulations (“Proposed Regulations”) state that the Internal Revenue Service and the U.S. Treasury have determined, that withholding ... ... withholding tax on “withholdable payments” to a Foreign ... passthru payments to withholding only if they are directly traceable to withholdable payments. (1) Withholding. A participating FFI is required to deduct and withhold tax with respect to payments made to recalcitrant account holders and nonparticipating ...