Understanding FATCA Passthru Payment Withholding for Global Taxpayers

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 ... 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 ... Today the IRS released proposed FATCA regulations which clarify the definition of “Investment Entity,” and eliminate withholding on payments of ... Passthru payments will become subject to FATCA withholding no earlier than. January 1, 2015. 3. Who is impacted by FATCA? Any entity making a ... which would thus not be subject to withholding before the foreign passthru payment ... • To properly allocate any FATCA withholding tax ... 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 ... 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 ... Under the tax code, entities that fail to comply with FATCA may be subject to a 30% withholding tax on (i) U.S.-source income, (ii) gross proceeds from the sale ... FATCA withholding for U.S. source gross proceeds will begin January 1, 2017. Passthru payments will become subject to FATCA withholding no earlier than January ... The elimination of FATCA withholding on gross proceeds and non-cash insurance premiums that are described above also apply to payments made to ...