Unlocking the Secrets of FATCA Passthru Payment Withholding

FATCA creates a new information reporting and withholding regime for payments made to certain foreign ... In addition, an FFI must withhold 30% on any passthru ... The Proposed Regulations would defer the withholding requirement on a Foreign Passthrough Payment made to nonparticipating FFIs or recalcitrant ... Specifically, the proposed regulations eliminate withholding on payments of gross proceeds, defer withholding on foreign passthru payments ... The 30% withholding tax applies to all payments that are 'withholdable payments'. This is a very wide definition and includes a variety of US ... ... withholding on payment of gross proceeds (definition of FATCA ... passthru payments (until 2 years after the definition of such ... ... Tax Compliance Act (FATCA) and chapter 3 of the Internal Revenue Code. ... withholding on foreign passthru payments. These provisions represent ... ... payments” until two years after final regulations defining foreign passthru payments are published. Foreign financial institutions located in jurisdictions ... ... FATCA.60 Withholding by participating FFIs begins on payments made after 31 December 2013.61 Withholding on foreign passthru payments is ... However, Participating FFIs generally will be required to report (but not withhold on) foreign passthru payments made to non-Participating FFIs. The current proposed FATCA regulations (“Proposed Regulations”) state that the Internal Revenue Service and the U.S. Treasury have determined, that withholding ...