The Power of Foreign Passthru Payments A Guide to Maximizing Your Profits in 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 ... "Grandfathered obligations" also include: (i) any obligation that can produce a "foreign passthru payment" but not a Withholdable Payment that ... Federal law changes enacted December 22, 2017, require U.S. shareholders to pay a federal transition tax on the untaxed foreign earnings of ... With respect to withholding on passthru payments, the Proposed Regulations indicate that withholding will occur no earlier than January 1, 2017, ... Further Suspension of Potential “Foreign Passthru Payment” Withholding. FATCA provides that certain payments by an FFI to a non-compliant ... ... foreign passthru payments before January 1, 2017. Instead, until withholding applies, to reduce incentives for nonparticipating FFIs to use participating ... Here, FATCA imposed withholding to on these “foreign pass-through payments” so that U.S. citizens could not avoid U.S. taxation by moving ... ... payments made on or after January 1, 2019;; Defer the effective date for withholding on foreign passthru payments, a “passthru payment ... Similar to withholding on gross proceeds, Treasury and the IRS have previously deferred the date when withholding on foreign passthru payments ... Withholding on foreign passthru payments will not begin before January 1, 2017, although transitional reporting of payments of certain FDAP ...