Unlocking the Power of FATCA Passthru Payment Withholding for Tax Efficiency

Specifically, the proposed regulations eliminate withholding on payments of gross proceeds, defer withholding on foreign passthru payments ... Under prior FATCA regulations, a 30 percent withholding tax was required on payments of gross proceeds to certain foreign entities made after ... imposes withholding on so-called foreign passthru payments. Withholding does not apply to on payments to a financial institution that ... 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. 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.”. The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements. January 1, 2019: Withholding on “foreign passthru payments” will become effective the later of January 1, 2019 or the date of publication of the ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... Tracing methodology for calculating FATCA withholding on passthru payments and election to avoid passthru payment withholding. In addition ...