Unlocking FATCA Pass-Through Payments A Step-by-Step Guide for 2017

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 ... alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden. 3. Documentation of ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold on a ... The rules for defining a pass-through payment are expected to be enormously complex, and administratively burdensome to implement. U.S. Treasury ... Annual FATCA reporting will be done on new IRS Form 8966 (FATCA Report), which the Preamble announces that the IRS will release in the near ... A passthru payment that is a withholdable payment would be subject to FATCA ... payments made before January 1, 2017. Instead, participating FFIs would ... FATCA imposes a 30% US withholding tax on withholdable payments made to certain FFIs and non-financial foreign entities (NFFEs) that do not meet specific ... - Withhold tax on foreign passthru payments made to recalcitrant accounts and nonparticipating ... reported in years 2016 and 2017, with ... ▫ Should generally neither be subject to FATCA withholding on payments they receive, nor required to apply passthru ... 2017. Of course ... Participating FFIs are not required to withhold on foreign passthru payments until the later of January 1, 2017 or six months after the date on which Treasury ...