FATCA Pass-Through A Comprehensive Evaluation for 2017

potentially foreign pass thru payments for calendar year. 2017. 2014. 2013. 2012. Page 15. PwC. (1) IGA: Intergovernmental Agreement. (2) ... As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... ▫ Proposed FATCA regulations issued Feb. 2012; final regs ... 1, 2017 – Earliest date to apply w/h on passthru payments. (pending ... to (i) non-FATCA-compliant foreign ... 2017, the earliest. Additional regulations will be issued to provide guidance on passthru payments. On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance ... The February Proposed Regulations extend the date on which FATCA withholding begins on foreign pass-thru payments from 1 January 2015 to 1 January 2017. pending FATCA and non-FATCA related U.S. ... foreign passthru payments” will not be subject to withholding any earlier than. January 1, 2017. Deferral of Effective Date of “Passthru Payment” Rules. The proposed regulations defer until at least 2017 the application of the rules ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income ... With respect to withholding on passthru payments, the Proposed Regulations indicate that withholding will occur no earlier than January 1, 2017, ...