Unlocking FATCA Passthru Payment Withholding A Key to Global Tax Efficiency

The elimination of FATCA withholding on gross proceeds and non-cash insurance premiums that are described above also apply to payments made to ... 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.”. Based on prior guidance, the foreign passthru payment withholding ... □ Apply FATCA withholding on withholdable payments and foreign passthru payments to ... Passthru payments will become subject to FATCA withholding no earlier than. January 1, 2015. 3. Who is impacted by FATCA? Any entity making a ... 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 ... Similar to the underlying rationale in relation to gross proceeds withholding, our view is that foreign passthru payment withholding is no longer required to ... FFIs are expected to enter into PFFI agreements that will require them to withhold on foreign pass-through payments before Treasury actually explains which ... ... withholding tax on “withholdable payments” to a Foreign ... passthru payments to withholding only if they are directly traceable to withholdable payments. Additionally, PFFIs must withhold 30 percent of any passthru payment to a nonparticipating FFI or account holders who refuse to release their. ... withholding on foreign-source passthru payments will begin no earlier than 2017. Thus, a non-participating foreign fund could be subject to 30% withholding ...