Mastering FATCA Passthru 2017 A Guide for International Taxpayers

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On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance ... "Under the passthru payment provision in FATCA, which takes effect in 2017, Wegelin does not have to have a direct relationship with the United ... ... 2017 in any case. Understandably, however, parties to non-US ... foreign passthru payments (Treas. Reg. § 1.1471- 2(b)(2)(i)(B)). 6 ... pending FATCA and non-FATCA related U.S. ... foreign passthru payments” will not be subject to withholding any earlier than. January 1, 2017. Controversially, FATCA orders every foreign bank to track down ... foreign passthru payments before January 1, 2017. Until withholding ... alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 3. Documentation of ... No withholding on foreign passthru payments until, at least, January 1, 2019;; Extension of time until January 1, 2017, to use limited ... Under FATCA, certain types of financial institutions are required to register with the IRS or face a very significant penalty of 30 per cent withholding tax. The pass-thru concept clearly takes FATCA beyond US territorial limits and ... deferred until after 1 January 2017. Complying with FATCA. The original ... FATCA was the revenue-raising portion of the 2010 domestic jobs stimulus bill, the Hiring Incentives to Restore Employment (HIRE) Act, and was enacted as ...
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