Unlocking the Potential of Foreign Passthru Payments A Step-by-Step Guide for 2017

Second, withholding on foreign passthru payments prevents nonparticipating FFIs from avoiding FATCA by investing in the. United States through a ... No earlier than January 1, 2017 - Withholding on Foreign Passthru Payments begins. Intergovernmental Agreements. Many foreign governments ... 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 ... In the proposed Treasury regulations implementing FATCA, the Treasury has reserved on the definition of "foreign pass-through payments" that are ... Income Subject to Tax Withholding; Estimated Payments; Penalties, Interest and Other Additions ... Foreign Derived Intangible Income §250. Allows deduction equal ... ... Payments (“Proceeds Payments ... 2017. • The grandfather date for obligations giving rise to foreign passthru payments or dividend equivalents. 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 ... Deferral of withholding on “foreign passthru payments. “An FFI that has an agreement described in Code Sec. 1471(b) in effect with IRS is ... (vi) Offshore payments of U.S. source FDAP income prior to 2017 (transitional). ... (2) Special rule for foreign passthru payments and payments of gross ... The proposed regulations extend FATCA's “grandfathering” period, delay the effective date for withholding on foreign-source passthru payments, provide potential ...