FATCA Pass-Through Payments A Compliance Roadmap for 2017

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- ... As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... Thus, a nonparticipating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... Further Suspension of Potential “Foreign Passthru Payment” Withholding. FATCA provides that certain payments by an FFI to a non-compliant ... January 1, 2019: Withholding on “foreign passthru payments” will become effective the later of January 1, 2019 or the date of publication of the ... FATCA seeks to accomplish this goal by requiring foreign ... Delay withholding on foreign "passthru payments" until at least 2017. ... 2017 for offshore U.S. source income, gross proceeds and foreign passthru payments. FDAP income includes items such as compensation, dividends, interest ... A passthru payment that is a withholdable payment would be subject to FATCA ... payments made before January 1, 2017. Instead ... Background · Removing FATCA withholding on payments of gross proceeds from the regulations · Deferring withholding on foreign pass-through ... alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 3. Documentation of ...