FATCA is a new information reporting regime from the US. Although FATCA's primary impact is on foreign financial institutions, non-financial groups and entities are also subject to FATCA in their role as a US payor/withholding agent or as a foreign payee/recipient of payments subject to FATCA. As such, FATCA will impose additional compliance requirements on non-financial groups. In cases where insufficient disclosures are made, the US payor/withholding agent will be required to withhold a 30 percent tax from such payments.
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