Navigating the Labyrinth of FATCA Pass-Through Payments 2017 Edition

Withholding on passthru payments prior to January 1, 2017 will be limited to payments by participating FFIs of U.S. source FDAP, such as payments of interest or ... FATCA imposes a 30% US withholding tax on withholdable payments made to certain FFIs and non-financial foreign entities (NFFEs) that do not meet specific ... Under FATCA, a passthru payment is defined as “any withholdable payment or other ... January 1, 2017,24 and discussed the existence of the ... Importantly, from 1 January 2017,. Participating FFIs must deduct withholding on payments to non-participating or uncooperative FFIs (“passthru payments”) and ... Such an FFI would be treated as a. Participating FFI (PFFI). 8. What are the consequences to an FFI of not complying with FATCA? Non-compliance potentially ... ... foreign passthru payments before January 1, 2017. Instead, until withholding applies, to reduce incentives for nonparticipating FFIs to use participating ... alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 3. Documentation of ... A passthru payment that is a withholdable payment would be subject to FATCA ... payments made before January 1, 2017. Instead, participating FFIs would ... Lastly, under the Proposed Regulations, withholding will not be required of FFIs with respect to pass-through payments before January 1, 2014, ... The FATCA regulations reserve on the definition of the term “foreign passthru payment.”7 In the meantime, a transitional rule provides that a ...