Unlocking the Complexity of FATCA Passthru Payment Withholding

withholding on certain payments (“Withholdable Payments”). ... Deferral of FATCA Withholding on Foreign Pass-thru Payments: “Foreign Pass-thru. 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 ... ... withholding on payment of gross proceeds (definition of FATCA ... passthru payments (until 2 years after the definition of such ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... imposes withholding on so-called foreign passthru payments. Withholding does not apply to on payments to a financial institution that ... Eliminate U.S. withholding under FATCA on payments ... Impose passthru payment withholding on payments to recalcitrant account holders, to. ... withholding on foreign-source passthru payments will begin no earlier than 2017. Thus, a non-participating foreign fund could be subject to 30% withholding ... ... FATCA.60 Withholding by participating FFIs begins on payments made after 31 December 2013.61 Withholding on foreign passthru payments is ... Under FATCA, US-based funds are treated as US financial institutions (USFIs) and are required to withhold on payments to non-US entity investors who refuse 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 ...