Foreign Passthru Payments A Gateway to Tax Optimization in 2017

With respect to withholding on passthru payments, the Proposed Regulations indicate that withholding will occur no earlier than January 1, 2017, ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed to work together, along with other partners, to develop a practical and ... ... passthru payments (“foreign passthru payments”) starting in 2017. The term “withholdable payment” means (1) any payment of U.S. source FDAP ... Withholding may also apply to non-US source payments because of the concept of 'passthru payments' (see below). How to avoid the withholding tax. ... payments to foreign payees if such payees do not comply with FATCA." The U.S. has yet to comply with FATCA itself, because as of 2017, it has not yet ... No earlier than January 1, 2017 - Withholding on Foreign Passthru Payments begins. Intergovernmental Agreements. Many foreign governments ... The regulations reserve on the definition of a foreign passthru payment, but do provide that a participating FFI does not have to withhold on a foreign passthru ... ... foreign income of such corporation determined as of December 31, 2017. ``(b ... ``(3) Exceptions for payments otherwise treated as base erosion payments ... After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... alternative approach to achieve the policy objectives of foreign passthru payment ...