Unlocking FATCA Pass-Through Payments A 2017 Guide for Foreign Financial Institutions

ending in 2017. If an institution fails to comply ... withholding on “Passthru” payments (income payments from an FFI to a foreign individual or entity. PFFI. Participating Foreign Financial Institution as defined in the US FATCA regulations ... 2017. The fund should also perform pre-existing account due ... 31, 2018, or the date of the publication of the final Treasury Regulations defining the term Foreign Passthrough Payment. ... 2017 (the 2017 ... Background · Removing FATCA withholding on payments of gross proceeds from the regulations · Deferring withholding on foreign pass-through ... - Withhold tax on foreign passthru payments made to recalcitrant accounts and nonparticipating ... reported in years 2016 and 2017, with ... final regulations are published defining the term foreign passthru payment. ... GIINs until January 1, 2017. For payments made to a ... As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... A passthru payment that is a withholdable payment would be subject to FATCA ... payments made before January 1, 2017. Instead ... ... 2017. FATCA is intended to prevent U.S. taxpayers from ... payments” and on foreign “passthru” payments that such foreign entities receive. Further Suspension of Potential “Foreign Passthru Payment” Withholding. FATCA provides that certain payments by an FFI to a non-compliant ...