FATCA Pass-Through A Comprehensive Analysis for 2017

1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... Under the 2014 temporary regulations, such substitute payments are subject to withholding if paid after January 1, 2017 ... foreign passthru payment. As announced ... The FATCA regulations currently reserve on the definition of the term “foreign passthru payment. ... 2017, or the date of publication in ... The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. Reporting on gross proceeds is to begin in. 2017. Passthru Payments. The proposed regulations would provide that withholding is not required ... Participating FFIs are not required to withhold on foreign passthru payments until the later of January 1, 2017 or six months after the date on which Treasury ... • FATCA Transitional Rules for Gross Proceeds and Foreign Passthru Payments ... withholding from the original 1st January 2017 to the new starting ... Congress passed the Foreign Account Tax Compliance Act (FATCA) in 2010. FATCA requires both individual taxpayers and foreign financial institutions (FFIs) ... just a starting point and only addressed some pieces of the basic FATCA structural framework. ... the IRS, and withhold on “passthru payments” (withholdable ...