FATCA Pass-Through Payments A Guide for Taxpayers and Non-U.S. Entities

In 2010, Congress passed the Foreign Account Tax Compliance Act (FATCA), to reduce tax evasion by US taxpayers holding funds in foreign accounts. ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015-66, this ... After months of waiting, the Treasury Department (“Treasury”) released proposed Foreign Account Tax Compliance Act (“FATCA”) “withholdable ... Participating FFIs are not required to withhold on foreign passthru payments until the later of January 1, 2017 or six months after the date on which Treasury ... ... passthru payments, and provide that withholding on foreign-source passthru payments will begin no earlier than 2017. Thus, a non-participating foreign ... Withholding on Foreign Passthru Payments will begin no earlier than January 1, 2017. The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 3. Documentation of ... This obligation was included as a temporary solution to the requirement to withhold on 'foreign passthru payments' which is included in the US provisions. Under ... Under FATCA and the Proposed Regulations, any payment made under “an obligation” (as defined in the Proposed Regulations) outstanding on January ...