The Insider's Guide to FATCA Passthru Payment Withholding Strategies

withholding agent makes a payment of U.S. source FDAP income to a participating foreign ... payment of a withholdable payment or a foreign pass thru payment.”. ... withholding on foreign-source passthru payments will begin no earlier than 2017. Thus, a non-participating foreign fund could be subject to 30% withholding ... The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. 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 ... A withholding agent must withhold 30 percent of any withholdable payment made after June 30, 2014, to a foreign financial institution (FFI) (see ... Importantly, from 1 January 2017,. Participating FFIs must deduct withholding on payments to non-participating or uncooperative FFIs (“passthru payments”) and ... Under prior FATCA regulations, a 30 percent withholding tax was required on payments of gross proceeds to certain foreign entities made after ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... January 1, 2019: Withholding on “foreign passthru payments” will become effective the later of January 1, 2019 or the date of publication of the ... Based on prior guidance, the foreign passthru payment withholding ... □ Apply FATCA withholding on withholdable payments and foreign passthru payments to ...