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Email On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA. Under the proposed regulations, gross proceeds from the sale or other disposition of an asset will not be subject to FATCA withholding, and passthru payments will not be subject to FATCA withholding any earlier than two years after the publication of final regulations that define the term “foreign passthru payment.” The proposed regulations also eliminate FATCA withholding on certain insurance premiums and provide other helpful guidance. https://www.cadwalader.com/resources/clients-friends-memos/tax-update-irs-trims-back-fatca