Unveiling the Impact of FATCA Pass-Through Payments on 2017 Tax Strategies

... (FATCA) regime. The proposed regulations would eliminate withholding on payments of gross proceeds, defer withholding on foreign passthru ... The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... 1474, commonly referred to as FATCA) requires withholding agents to withhold 30% of certain payments to a foreign financial institution (FFI) ... effective alternative approach to achieve the policy objectives of foreign passthru payment and gross proceeds withholding that minimizes burden ... Deferral of Effective Date of “Passthru Payment” Rules. The proposed regulations defer until at least 2017 the application of the rules ... ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015-66, this ... ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015 ... The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents under Section 871(m) of the Internal ... o U.S. credit union FATCA due diligence and withholding begin January 1, 2017 ... (“foreign passthru payment” will be defined in a future IRS ...