FATCA Pass-Through Payments 2017 A Compliance Blueprint

U.S. withholding tax will apply to foreign passthru payment to a recalcitrant account holder or a nonparticipating FFI that is made after the ... 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 ... pending FATCA and non-FATCA related U.S. ... foreign passthru payments” will not be subject to withholding any earlier than. January 1, 2017. Potential 30% withholding tax is payable on all interest and fees (and from January 2017 on principal) paid by US borrower and paid from US ... ... payments to foreign payees if such payees do not comply with FATCA." The U.S. has yet to comply with FATCA itself, because as of 2017, it has not yet ... Under FATCA, a passthru payment is defined as “any withholdable payment or other ... January 1, 2017,24 and discussed the existence of the ... ... passthru payments” (pay- ments attributable to withholdable payments) made to ... foreign pass thru payments until January 1, 2017, two years later than in. Under FATCA and the Proposed Regulations, any payment made under “an obligation” (as defined in the Proposed Regulations) outstanding on January ... It is expected that regulations will define the concept before 2017 to permit foreign passthru payment withholding to begin in 2017. 21 January 2013. 31, 2018, or the date of the publication of the final Treasury Regulations defining the term Foreign Passthrough Payment. ... 2017 (the 2017 ...