The Game-Changer Foreign Passthru Payments 2017 for Global Dominance

Foreign pass-thru payments ... withholding on such payments will be required until, at the earliest, January 1, 2017. (vi) Offshore payments of U.S. source FDAP income prior to 2017 (transitional). ... (2) Special rule for foreign passthru payments and payments of gross ... ... Payments (“Proceeds Payments ... 2017. • The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents. U.S. withholding tax will apply to foreign passthru payment to a recalcitrant account holder or a nonparticipating FFI that is made after the ... The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed to work together, along with other partners, to develop a practical and ... ... 2017, the effective date for withholding gross proceeds and foreign passthru payments. Therefore, the major withholding concern is the residual withholding ... January 1, 2017. • FATCA withholding begins on certain gross ... Payments treated as foreign passthru payments may be treated as ... The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ...