The Ultimate Blueprint for Foreign Passthru Payments in 2017

"Grandfathered obligations" also include: (i) any obligation that can produce a "foreign passthru payment" but not a Withholdable Payment that ... Delay in withholding on passthru payments that are not withholdable payments ... payments made before January 1, 2017. Instead, participating FFIs would ... January 1, 2017. Withholding on foreign passthru payments. The Proposed Regulations reserve on the definition of a foreign passthru payment; the term ... 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. Thus, a nonparticipating foreign fund could be subject to 30% withholding on any foreign-source passthru payments that it receives from a participating foreign ... ... Pass-through Payment legislation is enacted, no earlier than 2017. ... foreign passthru payments. This withholding will now not be required ... 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. Deferring withholding on foreign pass-through payments; Eliminating ... foreign TIN for a post-2017 form requires a signature. Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... effective alternative approach to achieve the policy objectives of foreign ... FATCA withholding may be required for "foreign pass-through payments", which are expected to be the subject of future U.S. guidance. 11. What are the ...