Foreign Passthru Payments Your Guide to Tax Efficiency in 2017

More specifically, the problems with application of the new regulations to foreign-to-foreign substitute payments ... alternative, to pass through documentation ... ... 2017, 72 percent of expenses which would otherwise be deductible under ... Corporation franchise tax for foreign corporations, or other taxable foreign ... ... foreign passthru payments. Moreover, the proposed regulations delay withholding on foreign passthru payments until 2017 at the earliest. After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... There is no requirement to withhold on foreign passthru payments for payments made before. January 1, 2019 and therefore this requirement is ... Reporting on gross proceeds is to begin in 2017. Passthru Payments. The proposed regulations would provide that withholding is not required with ... Deferral of withholding on “foreign passthru payments. “An FFI that has an agreement described in Code Sec. 1471(b) in effect with IRS is ... This obligation was included as a temporary solution to the requirement to withhold on 'foreign passthru payments' which is included in the US provisions. able payments and (beginning no earlier than 1 January 2017) foreign passthru payments paid to a client that is not FATCA-compliant. Foreign passthru payments ... ... 2017, the scope of passthru payments will be expanded beyond withholdable payments to include foreign passthru payments. • Grandfathered ...