Unlocking the Mysteries of FATCA Pass-Through Payments for 2017

The Regulations further provide, as noted above, that an obligation will not give rise to a foreign passthru payment if it is entered into on or ... ... foreign passthru payments will begin;. (2) the use of limited ... For a payment made on or after January 1, 2017, a withholding agent ... In 2010, Congress passed the Foreign Account Tax Compliance Act (FATCA), to reduce tax evasion by US taxpayers holding funds in foreign accounts. 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 ... As mentioned above, the Regulations fail to address how "foreign passthru withholding" is to work in practice. ... 2017, being the earliest date ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015 ... Deferral of Effective Date of “Passthru Payment” Rules. The proposed regulations defer until at least 2017 the application of the rules ... "Under the passthru payment provision in FATCA, which takes effect in 2017, Wegelin does not have to have a direct relationship with the United ... Now, the fact is that the passthru payment concept has essentially been deferred until 2017, and even then, it's final form will need to be substantively ...