There will be mandatory reporting of consolidated recalcitrant account balances as well as the number of recalcitrant accounts held by every FATCA compliant FFI in IGA – Model 1 countries.
In addition, PFFIs (FATCA compliant Banks) may also be obliged to close Recalcitrant accounts after a certain period of time.
In non IGA/ IGA Model 2 jurisdictions a withholding tax of 30% imposed on any qualifying U.S. source withholdable payments.
Qualifying withholdable payments are defined as:
• Any payment of interest (including portfolio interest and original issue discount), dividends, rents, royalties, salaries, wages, annuities, licensing fees and other FDAP income, gains, and profits, if such payment is from sources within the United States
• Any gross proceeds from the sale or disposition of U.S. Property of a type that can produce interest or dividends
• Interest paid by foreign branches of U.S. banks Certain "foreign pass-through" payments will also be subject to FATCA withholding at a future date. These are defined as any payments that are attributable to U.S. source income.