The Essential Guide to Foreign Passthru Payments Unlocking Opportunities for 2017

... passthru payments (“foreign passthru payments”) starting in 2017. The term “withholdable payment” means (1) any payment of U.S. source FDAP ... RELEASE DATE 21 December 2017. 10 NON FINANCIAL FOREIGN ENTITIES ... 'foreign passthru payments' which is included in the US provisions. Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... payments that are not withholdable payments (foreign passthru payments) made ... payments before January 1, 2017. Instead, until withholding applies ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... effective alternative approach to achieve the policy objectives of foreign ... "Grandfathered obligations" also include: (i) any obligation that can produce a "foreign passthru payment" but not a Withholdable Payment that ... (vi) Offshore payments of U.S. source FDAP income prior to 2017 (transitional). ... (2) Special rule for foreign passthru payments and payments of gross ... Thus, a nonparticipating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... The February Proposed Regulations extend the date on which FATCA withholding begins on foreign pass-thru payments from 1 January 2015 to 1 January 2017. ... Payments (“Proceeds Payments ... 2017. • The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents.