FATCA Pass-Through Payments A Comprehensive Analysis for 2017

The underlying purpose of the passthru payment rule is to encourage. FFIs to enter into FFI agreements if they hold investments that produce payments are. Deferral of Effective Date of “Passthru Payment” Rules. The proposed regulations defer until at least 2017 the application of the rules ... withholding and reporting. Jan. 1, 2017. Start of FATCA withholding on gross proceeds payments. Earliest date to apply expanded withholding pass thru payments ( ... ... 2017. FATCA is intended to prevent U.S. taxpayers from ... payments” and on foreign “passthru” payments that such foreign entities receive. 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 FATCA regulations reserve on the definition of the term “foreign passthru payment.”7 In the meantime, a transitional rule provides that a ... 31, 2018, or the date of the publication of the final Treasury Regulations defining the term Foreign Passthrough Payment. ... 2017 (the 2017 ... The participating FFI must file Form 8966 on magnetic media (i.e., the FATCA Report XML) with the IRS on or before March 31 of the year ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ...