Stay Compliant with FATCA Pass-Through 2017 Essential Steps for Financial Institutions

to (i) non-FATCA-compliant foreign ... 2017, the earliest. Additional regulations will be issued to provide guidance on passthru payments. 2017), foreign pass-thru payments (not before January 1, 2017) and a payment of FDAP income that would be a withholdable payment if paid by a U.S. person. incomes/investments: for 'foreign pass-thru payments' withholding has been postponed to January 1, 2017 at the earliest. Pillar 4. Reporting. Fragmented ... As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... passthru payments starting in 2017. II. Grandfathered obligations: FATCA reporting and withholding will not apply to a payment under any ... In addition, the Treasury Department and the IRS intend to amend the regulations so that withholding on foreign passthru payments will not begin ... The FATCA regulations currently reserve on the definition of the term “foreign passthru payment. ... 2017, or the date of publication in ... No withholding on foreign passthru payments until, at least, January 1, 2019;; Extension of time until January 1, 2017, to use limited ... Moreover, the proposed regulations delay withholding on foreign passthru payments until 2017 at the earliest. Extension of the Transition ... ... 2017, the scope of passthru payments will be expanded beyond withholdable payments to include foreign passthru payments. • Grandfathered ...