Unveiling the Complexities of FATCA Pass-Through Payments in 2017

... 2017. FATCA is intended to prevent U.S. taxpayers from ... payments” and on foreign “passthru” payments that such foreign entities receive. More Grandfathering. The proposed regulations would exclude from the definition of withholdable payment and passthru payment any payments under ... Additionally, FATCA imposes a 30% withholding tax on Withholdable Payments and. Passthru Payments made to certain non-U.S. entities that are not FFIs ("Non- ... 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 ... 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 ... 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 ... ending in 2017. If an institution fails to comply ... withholding on “Passthru” payments (income payments from an FFI to a foreign individual or entity. This document contains proposed regulations eliminating withholding on payments of gross proceeds, deferring withholding on foreign passthru payments. ... 2017, the scope of passthru payments will be expanded beyond withholdable payments to include foreign passthru payments. • Grandfathered ... Background · Removing FATCA withholding on payments of gross proceeds from the regulations · Deferring withholding on foreign pass-through ...