Demystifying FATCA Pass-Through Payments A 2017 Guide

As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... ... (FATCA) regime. The proposed regulations would eliminate withholding on payments of gross proceeds, defer withholding on foreign passthru ... This obligation was included as a temporary solution to the requirement to withhold on 'foreign passthru payments' which is included in the US provisions. Under ... Further Suspension of Potential “Foreign Passthru Payment” Withholding. FATCA provides that certain payments by an FFI to a non-compliant ... effective alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 3 ... alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 2. Documentation of ... Under FATCA, a passthru payment is defined as “any withholdable payment or other ... January 1, 2017,24 and discussed the existence of the ... Withholding on passthru payments prior to January 1, 2017 will be limited to payments by participating FFIs of U.S. source FDAP, such as payments of interest or ... FATCA withholding generally will be required on payments made to FFIs ... passthru payments made after January 1, 2017. Additionally ... The rules for defining a pass-through payment are expected to be enormously complex, and administratively burdensome to implement. U.S. Treasury ...