FATCA Pass-Through A Strategic Framework for 2017 Compliance

Under FATCA, certain types of financial institutions are required to register with the IRS or face a very significant penalty of 30 per cent withholding tax. 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 ... 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. ... Foreign Account Tax Compliance Act ("FATCA"). FATCA is the government's ... passthru payments made after January 1, 2017. Additionally ... effective alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden ... account holders before January 1, 2017. The proposed regulations ... FATCA withholding on foreign passthru payments begins. Full ... The withholding tax is a 30% tax on “withholdable payments.” F.A.T.C.A. also requires participating F.F.I.s (“P.F.F.I.s”) to withhold on “passthru payments” ... on 'foreign pass thru payments' which is included in the US provisions. ... April 2017, a list of those persons must be sent to the TIA by 31 May 2017 so ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income ...