Foreign branches of U.S. financial institutions will be considered U.S. withholding agents and payees that are U.S. persons under the Foreign Account Tax Compliance Act, the IRS said in a huge year-end regulations package.
That means they have primary withholding responsibility for certain types of “withholdable” payments they may make—a critical question under the 2010 law, which requires foreign financial institutions to report U.S.-owned accounts to the Internal Revenue Service or face a potential 30-percent withholding tax.
That was just one of a host of clarifications released Dec. 30 ...
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