FATCA Pass-Through Payments 2017 A Step-by-Step Guide to Compliance

Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... The rules for defining a pass-through payment are expected to be enormously complex, and administratively burdensome to implement. U.S. Treasury ... ... passthru payments” (pay- ments attributable to withholdable payments) made to ... foreign pass thru payments until January 1, 2017, two years later than in. And, as noted above, proceeds of dispositions of any of these instruments that give rise to U.S. source payments—e.g., a termination payment on ... Now, the fact is that the passthru payment concept has essentially been deferred until 2017, and even then, it's final form will need to be substantively ... The Regulations further provide, as noted above, that an obligation will not give rise to a foreign passthru payment if it is entered into on or ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 2. Documentation of ... alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 3. Documentation of ... FATCA withholding generally will be required on payments made to FFIs ... passthru payments made after January 1, 2017. Additionally ...