FATCA Pass-Through Payments A Simplified Approach to Global Compliance in 2017

Withholding on passthru payments prior to January 1, 2017 will be limited to payments by participating FFIs of U.S. source FDAP, such as payments of interest or ... RELEASE DATE 21 December 2017. 10 NON FINANCIAL FOREIGN ENTITIES ... 'foreign passthru payments' which is included in the US provisions. able payments and (beginning no earlier than 1 January 2017) foreign passthru payments paid to a client that is not FATCA-compliant. Foreign passthru ... ... foreign passthru payments will begin;. (2) the use of limited ... For a payment made on or after January 1, 2017, a withholding agent ... The FATCA regulations reserve on the definition of the term “foreign passthru payment.”7 In the meantime, a transitional rule provides that a ... ▫ Should generally neither be subject to FATCA withholding on payments they receive, nor required to apply passthru ... 2017. Of course ... Such an FFI would be treated as a. Participating FFI (PFFI). 8. What are the consequences to an FFI of not complying with FATCA? Non-compliance potentially ... Under FATCA, a passthru payment is defined as “any withholdable payment or other ... January 1, 2017,24 and discussed the existence of the ... A passthru payment that is a withholdable payment would be subject to FATCA ... payments made before January 1, 2017. Instead ... ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015-66, this ...