Enhancing FATCA Pass-Through Payment Reporting for 2017

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payment and any “foreign passthru payment.” FFIs will not be ... FATCA withholding on foreign passthru payments begins no earlier than 1 January 2017. effective alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income Payment ... ... 2017 for offshore U.S. source income, gross proceeds and foreign passthru payments. FDAP income includes items such as compensation, dividends, interest ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015 ... FATCA imposes a 30% US withholding tax on withholdable payments made to certain FFIs and non-financial foreign entities (NFFEs) that do not meet specific ... Under FATCA and the Proposed Regulations, any payment made under “an obligation” (as defined in the Proposed Regulations) outstanding on January ... ... passthru payments” (pay- ments attributable to withholdable payments) made to ... foreign pass thru payments until January 1, 2017, two years later than in. Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ...
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