The Ultimate Guide to Foreign Passthru Payments Navigating the Complexity for 2017

Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... alternative approach to achieve the policy objectives of foreign passthru payment ... Withholding may also apply to non-US source payments because of the concept of 'passthru payments' (see below). How to avoid the withholding tax. The proposed regulations provide that withholding will not be required with respect to foreign source passthru payments paid to nonparticipating FFIs and ... ... 2017, the effective date for withholding gross proceeds and foreign passthru payments. Therefore, the major withholding concern is the residual withholding ... able payments and (beginning no earlier than 1 January 2017) foreign passthru payments paid to a client that is not FATCA-compliant. Foreign passthru payments ... January 1, 2017. • FATCA withholding begins on certain gross ... Payments treated as foreign passthru payments may be treated as ... Base erosion payments do not include gross receipts of a foreign taxpayer to the extent they are “effectively connected with a U.S. trade or ... TCJA also expanded the scope of foreign-sourced income subject to taxation within the United States and provides an incentive for multinational ... Foreign passthru payments made to recalcitrant account holders and ... 2017 or the date of publication of final regulations defining “foreign ... withholding tax on those payments from 1st January 2017 in any case. ... foreign passthru payments (Treas. Reg. § 1.1471-. 2(b)(2)(i)(B)). 6 ...