Optimizing FATCA Pass-Through Strategies for 2017 Success

During 2017, the committee continued its dialogue with IRS officials regarding reporting requirements under the Foreign Account Tax Compliance ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... 2017 (see the Appendix for a FATCA timeline). • Position of UK ... apply FATCA withholding on passthru payments to others. Under the ... FATCA seeks to accomplish this goal by requiring foreign ... Delay withholding on foreign "passthru payments" until at least 2017. The IRS issued proposed regulations under the Foreign Account Tax Compliance Act (FATCA) regarding withholding on certain payments that was ... This has now been deferred two years to 1 January 2017. 2. Grandfathering protection from passthru withholding extended. It was highly ... FATCA essentially forces many FFIs and other foreign entities to disclose to the IRS information about their US account holders and owners. After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... Accounts from 1 January 2017. Page 122. 122. For all New Individual ... withhold on 'foreign passthru payments' which is included in the US.