Mastering FATCA Pass-Through Payments A Blueprint for 2017

- Withhold tax on foreign passthru payments made to recalcitrant accounts and nonparticipating ... reported in years 2016 and 2017, with ... Importantly, from 1 January 2017,. Participating FFIs must deduct withholding on payments to non-participating or uncooperative FFIs (“passthru payments”) and ... 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 ... FATCA imposes new reporting and withholding obligations on foreign financial institutions and certain other foreign persons which must be complied with in order ... As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... The February Proposed Regulations extend the date on which FATCA withholding begins on foreign pass-thru payments from 1 January 2015 to 1 January 2017. The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents under Section 871(m) of the Internal ... ending in 2017. If an institution fails to comply ... withholding on “Passthru” payments (income payments from an FFI to a foreign individual or entity. 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... ... 2017 for offshore U.S. source income, gross proceeds and foreign passthru payments. FDAP income includes items such as compensation, dividends, interest ...