Mastering Foreign Passthru Payments Essential Strategies for 2017 Success

Second, withholding on foreign passthru payments prevents nonparticipating FFIs from avoiding FATCA by investing in the. United States through a ... With respect to withholding on passthru payments, the Proposed Regulations indicate that withholding will occur no earlier than January 1, 2017, ... 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 ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... Delay in withholding on passthru payments that are not withholdable payments ... payments made before January 1, 2017. Instead, participating FFIs would ... Payments treated as foreign passthru payments may be treated as ... January 1, 2017, gross proceeds from the sale or disposition of property of a type. ... foreign income of multinational corporations from tax. 20 percent deduction for pass-through income. The law adopted a new 20 percent ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... FATCA imposes new reporting and withholding obligations on foreign financial institutions and certain other foreign ... payments and “passthru” payments that such ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income ...