Maximizing Compliance with FATCA Pass-Through Payments in 2017

Under FATCA and the Proposed Regulations, any payment made under “an obligation” (as defined in the Proposed Regulations) outstanding on January ... This document contains proposed regulations eliminating withholding on payments of gross proceeds, deferring withholding on foreign passthru payments. Participating FFIs are not required to withhold on foreign passthru payments until the later of January 1, 2017 or six months after the date on which Treasury ... 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 ... final regulations are published defining the term foreign passthru payment. ... GIINs until January 1, 2017. For payments made to a ... A passthru payment that is a withholdable payment would be subject to FATCA ... payments made before January 1, 2017. Instead, participating FFIs would ... RELEASE DATE 21 December 2017. 10 NON FINANCIAL FOREIGN ENTITIES ... 'foreign passthru payments' which is included in the US provisions. able payments and (beginning no earlier than 1 January 2017) foreign passthru payments paid to a client that is not FATCA-compliant. Foreign passthru ... A passthru payment that is a withholdable payment would be subject to FATCA ... payments made before January 1, 2017. Instead ... ending in 2017. If an institution fails to comply ... withholding on “Passthru” payments (income payments from an FFI to a foreign individual or entity.