Revolutionizing FATCA Pass-Through Payments Your 2017 Guide

Under FATCA, a passthru payment is defined as “any withholdable payment or other ... January 1, 2017,24 and discussed the existence of the ... Further Suspension of Potential “Foreign Passthru Payment” Withholding. FATCA provides that certain payments by an FFI to a non-compliant ... Payments treated as foreign passthru payments may be treated as ... January 1, 2017, gross proceeds from the sale or disposition of property of a type. In general, the FATCA withholding tax applies to. “withholdable payments” made to an FFI, unless the FFI enters into an agreement with the IRS. (an “FFI ... The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents under Section 871(m) of the Internal ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... The FATCA regulations reserve on the definition of the term “foreign passthru payment.”7 In the meantime, a transitional rule provides that a ... 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 ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... 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 ...