Unraveling FATCA Pass-Through Payments for 2017 A Detailed Examination

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2017 (see the Appendix for a FATCA timeline). • Position of UK ... apply FATCA withholding on passthru payments to others. Under the ... ... (FATCA) regime. The proposed regulations would eliminate withholding on payments of gross proceeds, defer withholding on foreign passthru ... A “passthru payment” is defined in the regulations to mean a withholdable payment and any foreign passthru payment. The FATCA regulations ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... the loan (from 1 January 2017). □ If it enters into an FFI agreement ... foreign passthru payment and gross proceeds withholding that ... withholding and reporting. Jan. 1, 2017. Start of FATCA withholding on gross proceeds payments. Earliest date to apply expanded withholding pass thru payments ( ... A passthru payment that is a withholdable payment would be subject to FATCA ... payments made before January 1, 2017. Instead, participating FFIs would ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... effective alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden ... "Under the passthru payment provision in FATCA, which takes effect in 2017, Wegelin does not have to have a direct relationship with the United ...
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