Empowering Businesses with FATCA Pass-Through Payment Insights for 2017

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... passthru payments” (pay- ments attributable to withholdable payments) made to ... foreign pass thru payments until January 1, 2017, two years later than in. Potential 30% withholding tax is payable on all interest and fees (and from January 2017 on principal) paid by US borrower and paid from US ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income Payment ... This document contains proposed regulations eliminating withholding on payments of gross proceeds, deferring withholding on foreign passthru payments. ... 2017, or the date of publication in the Federal Register of final regulations defining foreign passthru payment. As announced in Notice 2015-66, this ... The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents under Section 871(m) of the Internal ... Under prior FATCA regulations, a 30 percent withholding tax was required on payments of gross proceeds to certain foreign entities made after ... the loan (from 1 January 2017). □ If it enters into an FFI agreement ... foreign passthru payment and gross proceeds withholding that ... Foreign passthru payments made to recalcitrant account holders and nonparticipating FFIs by a participating FFI are also subject to withholding; ... "Passthru" Payments. Under the Proposed Regulations, withholding will not be required with respect to "foreign passthru payments" before January ...
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