Unlocking the Potential of Foreign Passthru Payments A Blueprint for 2017 Success

(4) Foreign passthru payments. A participating FFI is not required to deduct ... For rules that apply beginning on January 23, 2013 and before January 6, 2017 ... January 1, 2017. • FATCA withholding begins on certain gross ... Payments treated as foreign passthru payments may be treated as ... "Grandfathered obligations" also include: (i) any obligation that can produce a "foreign passthru payment" but not a Withholdable Payment that ... payments that are not withholdable payments (foreign passthru payments) made ... payments before January 1, 2017. Instead, until withholding applies ... After January 1, 2017, FATCA will also apply to payments that are not purely U.S. sourced (“foreign passthru payments”). In the future, the ... The proposed regulations reserve on when payments by foreign ... foreign "passthru payments" until January 1, 2017. The proposed ... ... foreign income of multinational corporations from tax. 20 percent deduction for pass-through income. The law adopted a new 20 percent ... 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 ... effective alternative approach to achieve the policy objectives of foreign ... ... 2017, 72 percent of expenses which would otherwise be deductible under ... Corporation franchise tax for foreign corporations, or other taxable foreign ...