Unleash the Benefits of Foreign Passthru Payments in 2017

Deferring withholding on foreign pass-through payments; Eliminating ... foreign TIN for a post-2017 form requires a signature. (vi) Offshore payments of U.S. source FDAP income prior to 2017 (transitional). ... (2) Special rule for foreign passthru payments and payments of gross ... Minimum 10 percent U.S. federal corporate income tax on foreign related-party payments by certain large U.S. corporations or non-U.S. ... Additionally, FATCA imposes a 30% withholding tax on Withholdable Payments and. Passthru Payments made to certain non-U.S. entities that are not FFIs ("Non- ... With respect to withholding on passthru payments, the Proposed Regulations indicate that withholding will occur no earlier than January 1, 2017, ... 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 ... Withholding on Foreign Passthru Payments will begin no earlier than January 1, 2017. TCJA also expanded the scope of foreign-sourced income subject to taxation within the United States and provides an incentive for multinational ... proceeds until some point in 2017, under Article 2. ... The IRS received comments to the effect that obligations that may give rise to foreign passthru payments ... Treatment of Passthru Payments and Gross Proceeds. The Parties are committed ... alternative approach to achieve the policy objectives of foreign passthru payment ...