Unlocking the Potential of FATCA Pass-Through Payments in 2017

... payments to foreign payees if such payees do not comply with FATCA." The U.S. has yet to comply with FATCA itself, because as of 2017, it has not yet ... The underlying purpose of the passthru payment rule is to encourage. FFIs to enter into FFI agreements if they hold investments that produce payments are. ... 2017 for offshore U.S. source income, gross proceeds and foreign passthru payments. FDAP income includes items such as compensation, dividends, interest ... The proposed regulations defer withholdings on pass-through payments. A pass-through payment is any payment made by a foreign financial ... "Passthru" Payments. Under the Proposed Regulations, withholding will not be required with respect to "foreign passthru payments" before January ... Importantly, from 1 January 2017,. Participating FFIs must deduct withholding on payments to non-participating or uncooperative FFIs (“passthru payments”) and ... 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 ... 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 ... After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... 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 ...