No, we don't. Under the new FATCA regulations, withhold-able payments do not include foreign exchange payments. Although gains on foreign exchange contracts are generally reported to the IRS as gross proceeds, FATCA regulations appear to apply to proceeds from the sale or disposition of property capable of producing interest or dividends from sources within the United States. Of note, this is subject to change if FATCA regulations are amended or revised. Please consult a qualified tax professional for additional assistance.
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