FATCA Pass-Through A Critical Analysis for 2017

The IRS issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) regarding withholding on certain payments that was ... As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... The final regulations provide that an FFI is not required to withhold on foreign passthru payments until the later of January 1, 2017, or six months after the ... 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. Under FATCA, payments to foreign financial ... Withholding with respect to foreign passthru payments will not be required until 2017 at the. alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 3. Documentation of ... Participating FFIs (including Reporting Model 2 FFIs) are required to renew their FFI Agreements through the FATCA. ▫ Proposed FATCA regulations issued Feb. 2012; final regs ... 1, 2017 – Earliest date to apply w/h on passthru payments. (pending ... The table below shows regulations, rulings, notices, announcements, and other FATCA-related guidance or requirements.