Mastering FATCA Pass-Through Payments A Simplified Guide for 2017

And, as noted above, proceeds of dispositions of any of these instruments that give rise to U.S. source payments—e.g., a termination payment on ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... - Withhold tax on foreign passthru payments made to recalcitrant accounts and nonparticipating ... reported in years 2016 and 2017, with ... Thus, a nonparticipating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... 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 ... FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... "Under the passthru payment provision in FATCA, which takes effect in 2017, Wegelin does not have to have a direct relationship with the United ... ending in 2017. If an institution fails to comply ... withholding on “Passthru” payments (income payments from an FFI to a foreign individual or entity. The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ...