Foreign Passthru Payments The Essential Handbook for 2017

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... payments made on or after January 1, 2019;; Defer the effective date for withholding on foreign passthru payments, a “passthru payment ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... Thus, a nonparticipating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... FATCA withholding may be required for "foreign pass-through payments", which are expected to be the subject of future U.S. guidance. 11. What are the ... No withholding on foreign passthru payments until, at least, January 1, 2019;; Extension of time until January 1, 2017, to use limited ... ... foreign passthru payments before January 1, 2017. Instead, until withholding applies, to reduce incentives for nonparticipating FFIs to use participating ... The proposed regulations extend FATCA's “grandfathering” period, delay the effective date for withholding on foreign-source passthru payments, provide potential ... (from 1 January 2017); and. □ 'foreign passthru payments' (foreign source payments originating from an FFI, to the extent 'attributable to ... ... foreign corporation is a related party as defined in R.S. 47:605.1. Starting with the 2017 Franchise tax period, a limited liability company (L.L.C.) for ... Second, withholding on foreign passthru payments prevents nonparticipating FFIs from avoiding FATCA by investing in the. United States through a ...
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