IRS Released Draft Instructions for Filing CbC Reports

The IRS published instructions for filing Form 8975 and accompanying the draft Schedule A (Country-by-Country Report) that apply to US multinational companies with more than $850 million in annual consolidated gross income.

Background: IRS Reports

The U.S. issued the final rules requiring country-by-country reporting in June 2016. The draft Form 8975 and Schedule A (Form 8975) were released in December 2016. On February 23, 2017, the IRS issued additional guidance in the General Instructions paper, which is based on the OECD BEPS project (Base Erosion and Profit Shifting) guidance on Country-by-Country reporting.

Content of Reported data

Under the Form 8975, US multinationals are required to list their business entities, indicating each entity’s tax jurisdiction (if any), country of organization and main business activity, and need to provide financial and employee information for each tax jurisdiction in which the U.S. MNE does business. The financial information includes revenues, profits, income taxes paid and accrued, stated capital, accumulated earnings, and tangible assets other than cash.

Filing Date

The first required reporting period for an ultimate parent entity is the 12-month reporting period that begins on or after the first day of a tax year of the ultimate parent entity that begins on or after June 30, 2016.

Source: IRS - Instructions on Form 8975

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