Unlock FATCA Passthru 2017 Maximizing Tax Efficiency

2017 (see the Appendix for a FATCA timeline). • Position of UK ... apply FATCA withholding on passthru payments to others. Under the ... This is linked to the reporting requirements, which do not mandate the reporting of gross proceeds until some point in 2017, under Article 2. Fatca preparation ... (from 1 January 2017); and. □ 'foreign passthru payments' (foreign source payments originating from an FFI, to the extent 'attributable to ... 2017, https://www.taxconnections.com/taxblog/fatca-causing-record ... FATCA “Passthrough Penalty”).68 Recalcitrant account holders are ... It is not yet clear when FATCA regulations dealing with passthru withholding will be issued, or even whether they will apply to loans at all ... Many foreign financial institutions have objected to FATCA on the basis that ... foreign pass thru payments until January 1, 2017, two years later than in. On February 8, 2012, the Internal Revenue Service ("IRS") issued proposed regulations (the "Proposed Regulations") which will implement the provisions of ... Importantly, from 1 January 2017,. Participating FFIs must deduct withholding on payments to non-participating or uncooperative FFIs (“passthru payments ... In 2010, the United States enacted FATCA to increase income tax reporting by US taxpayers on assets held in offshore accounts and through “Non-US Entities”. Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ...