Unleashing the Potential of Foreign Passthru Payments A Comprehensive Guide for 2017

The IRS has issued proposed new regulations that will further delay the imposition of withholding tax on foreign passthru payments. 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 ... 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 ... Under FATCA, participating foreign financial institutions (FFIs) must agree to withhold at the 30% rate on foreign passthrough payments made to ... There is no requirement to withhold on foreign passthru payments for payments made before. January 1, 2019 and therefore this requirement is ... be required to withhold on foreign passthru payments until January 1, 2017. Nevertheless, if the passthru payment itself is an Income ... FATCA imposes new reporting and withholding obligations on foreign financial institutions and certain other foreign ... payments and “passthru” payments that such ... Foreign pass-thru payments ... withholding on such payments will be required until, at the earliest, January 1, 2017. ... foreign income of multinational corporations from tax. 20 percent deduction for pass-through income. The law adopted a new 20 percent ... Second, withholding on foreign passthru payments prevents nonparticipating FFIs from avoiding FATCA by investing in the. United States through a ...