Mastering FATCA Pass-Through Payments for Foreign Trusts in 2017

FATCA seeks to accomplish this goal by requiring foreign ... Delay withholding on foreign "passthru payments" until at least 2017. This obligation was included as a temporary solution to the requirement to withhold on 'foreign passthru payments' which is included in the US provisions. Under ... the loan (from 1 January 2017). □ If it enters into an FFI agreement ... foreign passthru payment and gross proceeds withholding that ... ... 2017 for offshore U.S. source income, gross proceeds and foreign passthru payments. FDAP income includes items such as compensation, dividends, interest ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015-66, this ... More Grandfathering. The proposed regulations would exclude from the definition of withholdable payment and passthru payment any payments under ... payments and “foreign passthru payments” that the FFI makes to. NEW ... 2017 and the date that is six months after the publication of such ... FATCA compliant, but payments by such US corporation to a foreign ... Foreign passthru payment withholding is deferred until January 1, 2017. 31, 2018, or the date of the publication of the final Treasury Regulations defining the term Foreign Passthrough Payment. ... 2017 (the 2017 ...