Mastering the Nuances of FATCA Pass-Through Payments for 2017

FATCA subjects to withholding certain payments made by FFIs to nonparticipating FFIs and recalcitrant account holders (Foreign Passthrough ... "Passthru" Payments. Under the Proposed Regulations, withholding will not be required with respect to "foreign passthru payments" before January ... The participating FFI must file Form 8966 on magnetic media (i.e., the FATCA Report XML) with the IRS on or before March 31 of the year ... After months of waiting, the Treasury Department (“Treasury”) released proposed Foreign Account Tax Compliance Act (“FATCA”) “withholdable ... January 1, 2019: Withholding on “foreign passthru payments” will become effective the later of January 1, 2019 or the date of publication of the ... More Grandfathering. The proposed regulations would exclude from the definition of withholdable payment and passthru payment any payments under ... 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 ... As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... 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 ...