FATCA Pass-Through Payments A Comprehensive Guide for Non-Resident Aliens

... foreign passthru payments before January 1, 2017. Instead, until withholding applies, to reduce incentives for nonparticipating FFIs to use participating ... In general, the FATCA withholding tax applies to. “withholdable payments” made to an FFI, unless the FFI enters into an agreement with the IRS. (an “FFI ... FATCA imposes new reporting and withholding obligations on foreign financial institutions and certain other foreign persons which must be complied with in order ... Under prior FATCA regulations, a 30 percent withholding tax was required on payments of gross proceeds to certain foreign entities made after ... U.S. withholding tax will apply to foreign passthru payment to a recalcitrant account holder or a nonparticipating FFI that is made after the ... 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 ... 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 ... Under FATCA, a passthru payment is defined as “any withholdable payment or other ... January 1, 2017,24 and discussed the existence of the ... The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. Withholding on Foreign Passthru Payments will begin no earlier than January 1, 2017.