FATCA Pass-Through Payments A Compliance Guide for Foreign Financial Intermediaries

payments and “foreign passthru payments” that the FFI makes to. NEW ... 2017 and the date that is six months after the publication of such ... In 2010, Congress passed the Foreign Account Tax Compliance Act (FATCA), to reduce tax evasion by US taxpayers holding funds in foreign accounts. Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... Thus, a nonparticipating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... "Passthru" Payments. Under the Proposed Regulations, withholding will not be required with respect to "foreign passthru payments" before January ... More Grandfathering. The proposed regulations would exclude from the definition of withholdable payment and passthru payment any payments under ... Participating FFIs must withhold on any passthru payments made to their recalcitrant account holders and to nonparticipating FFIs. Similar to ... It is expected that regulations will define the concept before 2017 to permit foreign passthru payment withholding to begin in 2017. 21 January 2013. Additionally, FATCA imposes a 30% withholding tax on Withholdable Payments and. Passthru Payments made to certain non-U.S. entities that are not FFIs ("Non- ... ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015-66, this ...