Mastering FATCA Pass-Through Payments A Guide for U.S. Persons Abroad

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 ... pending FATCA and non-FATCA related U.S. ... foreign passthru payments” will not be subject to withholding any earlier than. January 1, 2017. The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents under Section 871(m) of the Internal ... Potential 30% withholding tax is payable on all interest and fees (and from January 2017 on principal) paid by US borrower and paid from US ... passthru payments starting in 2017. II. Grandfathered obligations ... as any withholdable payment and any foreign passthru payment; however, they ... the loan (from 1 January 2017). □ If it enters into an FFI agreement ... foreign passthru payment and gross proceeds withholding that ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... Under prior FATCA regulations, a 30 percent withholding tax was required on payments of gross proceeds to certain foreign entities made after ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... ... 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 ...