Unlock the Potential of Foreign Passthru Payments in 2017

Similar to withholding on gross proceeds, Treasury and the IRS have previously deferred the date when withholding on foreign passthru payments ... "Grandfathered obligations" also include: (i) any obligation that can produce a "foreign passthru payment" but not a Withholdable Payment that ... Participating FFIs are not required to withhold on foreign passthru payments until the later of January 1, 2017 or six months after the date on which Treasury ... (vi) Offshore payments of U.S. source FDAP income prior to 2017 (transitional). ... (2) Special rule for foreign passthru payments and payments of gross ... 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 ... Delay in withholding on passthru payments that are not withholdable payments ... payments made before January 1, 2017. Instead, participating FFIs would ... A US fund does not have to withhold on a Foreign Passthru Payment. Grandfathered Obligations. Payments on 'Grandfathered Obligations' and gross ... ... Payments (“Proceeds Payments ... 2017. • The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents. ... payments made on or after January 1, 2014, and “foreign passthru payments” will not be subject to withholding any earlier than. January 1, 2017. On December 22, 2017, President Donald Trump signed Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act (TCJA). The law added new section ...