The Ultimate Guide to Foreign Passthru Payments for 2017 Tax Season

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 ... The final regulations, like the proposed regulations, do not define foreign-source passthru payments,11 and provide that withholding on 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. Minimum 10 percent U.S. federal corporate income tax on foreign related-party payments by certain large U.S. corporations or non-U.S. ... Withholding on foreign passthru payments serves important purposes. ... Despite being attributable to the U.S. source payment, the payment made to ... There is no requirement to withhold on foreign passthru payments for payments made before. January 1, 2019 and therefore this requirement is ... (vi) Offshore payments of U.S. source FDAP income prior to 2017 (transitional). ... (2) Special rule for foreign passthru payments and payments of gross ... Federal law changes enacted December 22, 2017, require U.S. shareholders to pay a federal transition tax on the untaxed foreign earnings of ... Under existing regulations, certain other payments referred to as “foreign passthru payments” (term is not yet defined) may also become subject to withholding ... RELEASE DATE 21 December 2017. 10 NON FINANCIAL FOREIGN ENTITIES ... 'foreign passthru payments' which is included in the US provisions.