FATCA Pass-Through Payments A Step-by-Step Guide for U.S. Entities

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- ... ending in 2017. If an institution fails to comply ... withholding on “Passthru” payments (income payments from an FFI to a foreign individual or entity. After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... 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 ... o U.S. credit union FATCA due diligence and withholding begin January 1, 2017 ... (“foreign passthru payment” will be defined in a future IRS ... ... pass-through payments, 1 January. 2017. While these dates may seem distant, all FFIs and US persons who make payments to FFIs should start to take ... U.S. withholding tax will apply to foreign passthru payment to a recalcitrant account holder or a nonparticipating FFI that is made after the ... 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 ...