Unlocking the Potential of FATCA Pass-Through Payments Your Guide for 2017

After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... 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 ... ... 2017 for offshore U.S. source income, gross proceeds and foreign passthru payments. FDAP income includes items such as compensation, dividends, interest ... payment and any “foreign passthru payment.” FFIs will not be ... FATCA withholding on foreign passthru payments begins no earlier than 1 January 2017. Withholding on passthru payments prior to January 1, 2017 will be limited to payments by participating FFIs of U.S. source FDAP, such as payments of interest or ... ... foreign passthru payments before January 1, 2017. Instead, until withholding applies, to reduce incentives for nonparticipating FFIs to use participating ... In general, the FATCA withholding tax applies to. “withholdable payments” made to an FFI, unless the FFI enters into an agreement with the IRS. (an “FFI ... Lastly, under the Proposed Regulations, withholding will not be required of FFIs with respect to pass-through payments before January 1, 2014, ... payments and “foreign passthru payments” that the FFI makes to. NEW ... 2017 and the date that is six months after the publication of such ... Background · Removing FATCA withholding on payments of gross proceeds from the regulations · Deferring withholding on foreign pass-through ...