Unlocking the Value of FATCA Passthru Payments (2019)

A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed to work together, along with Partner Jurisdictions, to develop ... The regulations provided that withholding on Passthru. Payments will not begin before the later of January 1, 2019, or the date the final reg-. U.S. withholding tax will apply to foreign passthru payment to a recalcitrant account holder or a nonparticipating FFI that is made after the ... Further Suspension of Potential “Foreign Passthru Payment” Withholding. FATCA provides that certain payments by an FFI to a non-compliant ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... Specifically, a withholding agent will be required to begin FATCA withholding on withholdable payments made after June 30, 2014, on payments ... 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 tweaks kick "Passthru" withholding back to the future ... 2019 or such other date as may apply due to a change in FATCA. ... foreign passthru payment". This ... Although FATCA was enacted in 2008, the IRS extended several FATCA related effective dates and in particular extended until January 1, 2019, the ...