Foreign Passthru Payments The Ultimate Guide to Optimizing Your Global Strategy in 2017

... Payments (“Proceeds Payments ... 2017. • The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents. The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. Pass-through payments under FATCA are certain payments that would originate from a debtor payment, which passes through a foreign financial institution ... (from 1 January 2017); and. □ 'foreign passthru payments' (foreign source payments originating from an FFI, to the extent 'attributable to ... This obligation was included as a temporary solution to the requirement to withhold on 'foreign passthru payments' which is included in the US provisions. (4) Foreign passthru payments. A participating FFI is not required to deduct ... For rules that apply beginning on January 23, 2013 and before January 6, 2017 ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... In the proposed Treasury regulations implementing FATCA, the Treasury has reserved on the definition of "foreign pass-through payments" that are ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... "Grandfathered obligations" also include: (i) any obligation that can produce a "foreign passthru payment" but not a Withholdable Payment that ...