The Essential Guide to Foreign Passthru Payments Optimizing Strategies for 2017

Treatment of Passthru Payments and Gross Proceeds. The Parties are committed to work together, along with other partners, to develop a practical and ... ... foreign income of multinational corporations from tax. 20 percent deduction for pass-through income. The law adopted a new 20 percent ... Earliest date that withholding on foreign passthru payments may commence (PFFIs) ... year 2017) (WAs and PFFIs). 2013. Timeline of Certain Key Dates for ... Reporting on gross proceeds is to begin in 2017. Passthru Payments. The proposed regulations would provide that withholding is not required with ... 5 Prior payments of foreign partners' or members' withholding for taxable year shown above . ... Form 592-F is also used by pass-through entities to pass-through ... on passthru payments (that is, withholdable payments and foreign passthru payments) made to recalcitrant account holders of the FFI and. Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... 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. January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ...